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2013 (1) TMI 601 - HC - Income TaxPresumptive Taxation – Permanent establishment (PE) in India – India US DTAA - PGBP of the business of exploration, etc., of mineral oils – Deemed profit - 10% of any remuneration received by an assessee – A US enterprise, has no permanent establishment in India - Held that:- Article 7 of DTAA requires a non-resident US enterprise to have a permanent establishment in India for being taxed in India, otherwise it is not taxable in any view of the said treaty, even it received any remuneration in connection with any matter provided in Section 44BB. In favour of assessee
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