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Income Tax - Highlights / Catch Notes

Home Highlights April 2023 Year 2023 This

Income taxable in India - PE in India - Tax authorities below ...

April 14, 2023

Case Laws     Income Tax     AT

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 or arising out of such business connection, which is clear and explicit. It is established that assessee had no business connection or dependent agent PE or construction PE in India. The attribution of profit from off-shores supplies made to PGCIL to the alleged business connection or PE and application of Section 44BBB is not sustainable. - AT

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