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1. Whether the assessee had a PE in India - it is observed that the contractee is to provide office space with some other facilities to the employees of the assessee in...

2. Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income...

3. Accrual of income India - Service PE/ virtual service PE in India - computation of threshold date for constitution of service PE - The tribunal concluded that for AY...

4. 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...

5. Accrual of income in India - existence of PE - business profits attributable to the PE - Entire profits from supply of equipments and software cannot be attributed to...

6. Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on...

7. TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

8. Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

9. Income taxable in India - Fixed place PE in India - project office in India - none of the conditions of fixed place PE stand satisfied - the attribution of profit qua...

10. Income taxable in India - PE in India - Tax authorities below failed to appreciate the distinction between the existence of a business connection and the income accruing...

11. Existence of PE - addition on account of salary reimbursement cost treated as fee for technical services - the burden of proving that the foreign assessee has a PE in...

12. PE in India - Grouting activities - he establishment of PE in India is in respect of each assessment year only. Moreover, there is no bar in carrying on the activities...

13. Business connection in India - Existence of Fixed PE In India and service PE In India - s even if assumed that there is a PE in India of the assessee no profit can be...

14. Interest accrued/received to the Indian PE from its head office/overseas branches – concept of mutuality cannot override specific provision of law - once the interest...

15. 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)...