The matter regarding installation PE is to be verified by AO. If ...

Case Laws Income Tax

September 1, 2016

The matter regarding installation PE is to be verified by AO. If AO reaches a conclusion that there was installation PE, then the income has to be attributed considering the extent of functions performed in relation to installation. - AT

View Source

← Previous Next →

The matter regarding installation PE is to be verified by AO. If ...

Case Laws Income Tax

September 1, 2016

You may also like:

The assessee, a US-based company engaged in offshore sales of goods and software to customers in India, contended that it had no permanent establishment (PE) or...

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)...

Addition of unexplained expenditure u/s 69C - AO not verified the actual contents of seized material and addition made based on Report of the Special Auditor - AO is...

Installation PE in India - since no business activities were carried out by the assessee in India, it is unreasonable to conclude that the assessee has any PE in India.

The assessee did not have a Permanent Establishment (PE) in India, and the royalty income received during the year was taxable at 10% plus applicable surcharge and cess...

TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

Revision u/s 263 - AO made detailed inquiries regarding claim of LTCG before accepting the same - it was incumbent upon Pr.CIT to make inquiry so as to reach the...

AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions,...

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...

Whether the assessee had a PE in India - it is observed that the contractee is to provide office space with some other facilities to the employees of the assessee in...

The Authority for Advance Rulings (AAR) examined whether a Fixed Place Permanent Establishment (PE) or a Dependent Agent PE (DAPE) existed in India for the assessee. The...

Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The...

Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions...

Addition u/s 68 - In the given case, AO has not carried out any useful investigation but merely followed the previous pattern of investigation and completed the...

Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a...

Quick Updates: