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Income Tax - Highlights / Catch Notes

Home Highlights August 2019 Year 2019 This

Rate of tax applicable to PE of foreign entity - DTAA between ...


Japanese Bank's Permanent Establishment in India Taxed Equally to Indian Banks Under DTAA and Indian Income Tax Act.

August 21, 2019

Case Laws     Income Tax     HC

Rate of tax applicable to PE of foreign entity - DTAA between India and Japan - by virtue of Clause 24(2) of the said agreement and the statutory recognition thereof in Section 90(2), the PE of a Japanese entity(bank) in India could not have been charged tax at a rate higher than comparable Indian assessees carrying on the same activities - taxable @ applicable on Indian bank

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