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Income Tax - Highlights / Catch Notes

Home Highlights August 2023 Year 2023 This

Income deemed to accrue or arise in India - royalty income - ...


No Permanent Establishment in India: Project Sites in Bangaluru and Gurugram Under 183-Day Threshold for Royalty Income.

August 1, 2023

Case Laws     Income Tax     AT

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 project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT

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