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Income Tax - Highlights / Catch Notes

Home Highlights April 2014 Year 2014 This

Advance Ruling - The stage at which the permanent establishment ...


Linde and Samsung's Association of Persons deemed a tax resident in India, permanent establishment timing unaddressed.

April 29, 2014

Case Laws     Income Tax     HC

Advance Ruling - The stage at which the permanent establishment came into existence is a mixed question of fact and law. The Authority has not considered this question in view of its conclusion that Linde and Samsung had constituted an Association of Persons which was a tax resident entity in India for the purposes of the Act. - HC

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