Dependent Agent - Permanent Establishment - On facts it cannot ...

Case Laws Income Tax

June 3, 2012

Dependent Agent - Permanent Establishment - On facts it cannot be said that the Indian Representative has “habitually exercises” authority to conclude contracts. - Mauritius DTAA is not attracted in this case. - AT

View Source

← Previous Next →

Dependent Agent - Permanent Establishment - On facts it cannot ...

Case Laws Income Tax

June 3, 2012

You may also like:

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India -...

Existence PE - dependent agent Permanent Establishment - All the substantive parts of the key activities in making sales were done by DAIPL from India. This shows that...

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...

Revision u/s 263 by CIT - There is no such finding about the payment to the dependent agent being less than the arm’s length price of services rendered by the dependent...

Indo-Swiss DTAA - though eBay India and eBay Motors are dependent agents of the assessee, but do not constitute 'Dependent agent PEs' of the assessee - AT

Existence of Permanent establishment - pierce the veil - there is interlacing of activities and interlocking of funds between the assessee and its Indian subsidiary 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)...

Accrual of income in India - FTS - Existence of a PE - Determining income on presumptive basis attributable towards Permanent Establishment ("PE" ) - Tax Authorities...

TDS u/s 195 - Disallowance of commission income - there was no requirement for the assessee to deduct tax at source on such payments made to non-resident agents based...

TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

Liaison Office(LO) and Indian subsidiary - assessee is a company of Finland - LO cannot be constituted as Permanent Establishment of the assessee in India - HC

The Indian Liaison Office involves a “Permanent Establishment‟ for the applicant under Article 5.1 of the DTAA with USA - income attributable to Liaison office is...

Assessment in the hands of representative / agent - Chief Financial officer (CFO) of the non-resident assessee - Merely because those shares related to the Indian...

Income taxable In India - Taxability of compensation paid to the overseas Cricket Association for the termination of the agreement - Dependent Agent Permanent...

Quick Updates: