Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2023 Year 2023 This

Income deemed to accrue or arise in India - existence of Agency ...

Case Laws     Income Tax

March 18, 2023

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 record, we hold that the assessee does not have any PE in India. Therefore, in absence of PE, the business profits of the assessee cannot be taxed in India. Accordingly, the additions made by way of attribution of profit to the PE in India deserve to be deleted. - AT

View Source

 


 

You may also like:

  1. Income deemed to accrue or arise in India - Permanent establishment (PE) in India - unless a particular place is at the disposal of the assessee, that place cannot be...

  2. Income accrued in India - though the assessee had business connection, it did not have any fixed place PE or agency place PE in India, and, in the absence of any PE in...

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

  4. 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...

  5. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

  6. Income deemed to accrue or arise in India - Revenue has failed to establish on record through credible evidence that the assessee has a fixed placed PE in India through...

  7. 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...

  8. 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...

  9. The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such...

  10. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

  11. Accrual of income in India - FTS - Existence of a PE - Determining income on presumptive basis attributable towards Permanent Establishment ("PE" ) - Tax Authorities...

  12. Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

  13. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

  14. Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

  15. Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The...

 

Quick Updates:Latest Updates