TMI BlogAccrual of income in India - PE in India or not? - UK DTAA - Taxability of receipts from offshore supply...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) upheld applicability of section 44BB without addressing PE issue - Tribunal considered submissions and material on record, noting assessee's absence of presence for onshore activities and referring to previous decision in assessee's favor for A.Y. 2020-21 - Tribunal ruled in favor of the assessee, holding that section 44BB cannot be invoked to tax offshore supply receipts on a presumptive basis in absence of established PE. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
