Since no activities have been carried out by the Assessee in ...

Assessee's Business Activities in India Do Not Constitute Permanent Establishment Due to Lack of Direct Operations or Subcontractor Use.

February 15, 2017

Case Laws Income Tax AT

Since no activities have been carried out by the Assessee in India with respect of such maintenance activity, it is unreasonable to conclude that the business of the Assessee was carried out in India through such subcontractor, to constitute its PE in India - AT

View Source

← Previous Next →

Since no activities have been carried out by the Assessee in ...

Assessee's Business Activities in India Do Not Constitute Permanent Establishment Due to Lack of Direct Operations or Subcontractor Use.

February 15, 2017

Case Laws Income Tax AT

You may also like:

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...

TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

Income deemed to accrue or arise in India - Liaison Office (LO) as a Service PE or Dependent Agency Permanent Establishment (DAPE) - LO did not carry any activity,...

Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

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

Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an...

Establishment of Permanent Establishment (PE) in India - Onus is heavily upon the revenue to establish that that assessee’s activity had crossed the threshold period of...

This case deals with the accrual of income in India from exploration activities and the determination of whether the assessee has a Permanent Establishment (PE) in India...

Income deemed to accrue or arise in India - Permanent establishment (PE) in India - unless a particular place is at the disposal of the assessee, that place cannot be...

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...

Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The...

The recipients were non-residents without any permanent establishment or business connection in India. The services were rendered outside India for which commission was...

The High Court considered the validity of reassessment proceedings regarding the taxability of income without Permanent Establishment in India under India-Japan DTAA,...

Quick Updates: