PE in India - In order to conclude that Nortel India constitutes ...
Assessing Officer Must Prove Nortel India Finalized Contracts to Establish Dependent Agent Permanent Establishment Status.
May 10, 2016
Case Laws Income Tax HC
PE in India - In order to conclude that Nortel India constitutes a Dependent Agent PE, it would be necessary for the AO to notice at least a few instances where contracts had been concluded by Nortel India in India on behalf of other group entities. In absence of any such evidence, this view could not be sustained. - HC
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