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Income Tax - Highlights / Catch Notes

Home Highlights June 2020 Year 2020 This

PE in India - India-Spain DTAA - business profit carried out ...

Case Laws     Income Tax

June 4, 2020

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 assessment year 2007-08 for the activities relating to DPIR and engineering services from which the assessee has earned the revenue and same cannot be taxed as business profit carried out through PE in India. It is in the nature of FTS which is to be taxed in accordance with Article 13(4) of India-Spain DTAA

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