PE in India - activities of Research and development activities ...

R&D Activities Do Not Create Permanent Establishment in India; Taxable Only if Profits Accrue Locally - Article 7(1.

December 16, 2022

Case Laws Income Tax HC

PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that the issue of taxability would arise qua the respondent/assessee only if profits accrue to the respondent/assessee, and that too only to the extent they can be attributed to its PE in India. - HC

View Source

← Previous Next →

PE in India - activities of Research and development activities ...

R&D Activities Do Not Create Permanent Establishment in India; Taxable Only if Profits Accrue Locally - Article 7(1.

December 16, 2022

Case Laws Income Tax HC

You may also like:

Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer...

Income accrued or deemed to accrue in India - marketing and advertising rights that have been granted under the MAA [Marketing and Advertising Agreement'] - rights under...

Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

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...

Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

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...

Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an...

Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a...

Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

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 - income in respect of “off-shore supply” of equipment - DTAA between India and Austria - The part of the operations of supply agreement have...

Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees...

Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The...

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...

Quick Updates: