Fixed Place PE - Taxability of offshore supply of goods - ...

Income Tax

March 31, 2023

Fixed Place PE - Taxability of offshore supply of goods - Attribution of profits - once the basis of determination of total income itself is illegal due to violation of provisions of section 144C(10) and 144C(13) of the Act, the ultimate determination of total income in the final assessment order also becomes bad in law. - AT

View Source

← Previous Next →

Fixed Place PE - Taxability of offshore supply of goods - ...

Income Tax

March 31, 2023

You may also like:

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...

Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions...

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 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...

Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

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

Revision u/s 263 by CIT - profit attribution of a fixed place PE and the DAPE - Erroneous but not prejudicial to revenue order - Even if that computation of profit...

Accrual of income in India - PE in India or not? - UK DTAA - Taxability of receipts from offshore supply on presumptive basis u/s 44BB - Dispute Resolution Panel (DRP)...

Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

Income accrued in India - profit on supply of equipment - offshore supply - goods were sold from outside India, thus, the risk and title were also transferred outside...

Quick Updates: