TDS u/s 195 - it is only elementary that existence of PE is sine ...
Income Tax
June 2, 2017
TDS u/s 195 - it is only elementary that existence of PE is sine qua non only for taxation of business profits but that the foreign entity not having a PE in India does not come in the way of taxation of royalties - the payment for sharing of the SOPs, as is the case before us, indeed taxable as ‘royalties’ under the Indo German tax treaty - AT
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