Business connection in India - Existence of Fixed PE In India ...

March 12, 2016

Case Laws Income Tax AT

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 attributed to it as FAR (Functions performed, Assets deployed and Risk Assumed) such PE has already been compensated at arm's length price and therefore nothing more should be attributed to it. - AT

View Source

← Previous Next →

Business connection in India - Existence of Fixed PE In India ...

March 12, 2016

Case Laws Income Tax AT

You may also like:

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...

Income accrued in India - though the assessee had business connection, it did not have any fixed place PE or agency place PE in India, and, in the absence of any PE in...

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

Refund of Service Tax alongwith Interest - Export of services - even if a person has a fixed establishment in India, but if the services are provided and consumed in...

The assessee had artificially split the composite contract to avoid establishment of a permanent establishment (PE) in India and tax payment. The Assessing Officer (AO)...

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

Providing services of vessel management services in India - income of assessees engaged in such activities can be taxed u/s 44BB only if the two conditions are fulfilled....

PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

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...

Income taxable in India - Fixed place PE in India - project office in India - none of the conditions of fixed place PE stand satisfied - the attribution of profit qua...

Fixed place permanent establishments - India-USA DTAA - GE carried on business in India through its fixed place of business (i.e the premises), through the premises -...

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...

Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

Accrual of income India - Service PE/ virtual service PE in India - computation of threshold date for constitution of service PE - The tribunal concluded that for AY...

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....

Quick Updates: