Existence of Permanent establishment - services are rendered by ...

Case Laws Income Tax

April 26, 2014

Existence of Permanent establishment - services are rendered by the assessee through its employees and activities continued for a period of more than ninety days within twelve months period - JCB India constituted a service P.E of the assessee in India - AT

View Source

← Previous Next →

Existence of Permanent establishment - services are rendered by ...

Case Laws Income Tax

April 26, 2014

You may also like:

Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

Marketing and management services - Even the existence of the service per manent establishment in India will not make it taxable because of no involvement of such...

Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services...

Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and...

Existence of Permanent establishment - pierce the veil - there is interlacing of activities and interlocking of funds between the assessee and its Indian subsidiary in...

Permanent Establishment(PE) - if in vacation period, employee has not rendered any services in India, that period should not be included for counting 90 days stay -...

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

Taxability of salary income in India while rendering service in abroad - assessee is NRI - income accrued inside or outside India - assessee is a non-resident employee...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Taxability of employee cost reimbursements as Fee for Technical Services (FTS) under the India-Japan tax treaty. The assessee, a Japanese company, seconded employees...

TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits...

Classification of services - renting of immovable property service or Support Services of Business and Commerce - assessee has rendered composite services whereas as per...

TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in...

Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

Quick Updates: