Can the following be treated as NO PE Certificate from the foreign remittee for the purpose of withholding tax concession ?
We have a PE in India during the year but the services mentioned under Procurement Expense Agreement dt.......... are not connected with PE in India.
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The conditions as envisaged in the provisions related to withholding tax says about having a PE in India. So the expenses incurred is related to the PE or not, does not make any difference. But terms of agreement may give some insights to give a clear view.