Installation PE in India - since no business activities were ...

Assessee Not Liable for Permanent Establishment in India Due to Lack of Business Activity u/s 9.

August 4, 2018

Case Laws Income Tax AT

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.

View Source

← Previous Next →

Installation PE in India - since no business activities were ...

Assessee Not Liable for Permanent Establishment in India Due to Lack of Business Activity u/s 9.

August 4, 2018

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...

TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and...

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

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

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

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...

The case pertained to the taxability of royalty receipts in India for payments received by the assessee for the supply of software. The assessee's stance was that the...

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 taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

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...

Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities...

Permanent Establishment - Car is manufactured by the Audi AG outside India and constitutes a separate and independent activity. As noted earlier the car is sold to VW...

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...

Quick Updates: