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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