P.E. in India - SIPL was an independent agent under Article ...
Income Tax
August 24, 2017
P.E. in India - SIPL was an independent agent under Article 5(6)of the tax treaty between India and Holland, that the activities of the agent were carried out in its ordinary course of business, that the agent was not wholly and exclusively devoted to the assessee, that payments made to SIPL were at arm's length - Assessee does not have PE in India
View Source
