Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights February 2014 Year 2014 This

Existence of PE in India - Mutual Agreement Procedure - The MAP ...

Case Laws     Income Tax

February 11, 2014

Existence of PE in India - Mutual Agreement Procedure - The MAP procedure and agreement, is no doubt relevant but cannot be determinative or the primary basis to decide whether the assessee had PE in India. - HC

View Source

 


 

You may also like:

  1. Income accrued in India - PE in India - business service agreement/single unified agreement - On going through the sequence of activities and commentary of the OECD with...

  2. Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

  3. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

  4. Business connection in India - Existence of Fixed PE In India and service PE In India - s even if assumed that there is a PE in India of the assessee no profit can be...

  5. Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on...

  6. Income deemed to accrue or arise in India - Collection of membership fees - We are in agreement with the claim of the assessee that amount of profit that would be...

  7. Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of...

  8. Permanent Establishment (PE in India) - scope of the agreement - the Indian hotel, Swissotel Kolkata, satisfies all the three tests and does constitute a fixed place PE...

  9. Accrual of income in India - existence of DAPE - PE in India or not? - The ITAT previously ruled in favor of the Assessee regarding the existence of a fixed place PE....

  10. TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

  11. Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

  12. Accrual of income in India - FTS - Existence of a PE - Determining income on presumptive basis attributable towards Permanent Establishment ("PE" ) - Tax Authorities...

  13. Income taxable in India - PE in India - Tax authorities below failed to appreciate the distinction between the existence of a business connection and the income accruing...

  14. PE in India - Grouting activities - he establishment of PE in India is in respect of each assessment year only. Moreover, there is no bar in carrying on the activities...

  15. Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing...

 

Quick Updates:Latest Updates