Attributing income to the PE, under the DTAA - The income to the ...
Income Tax
October 31, 2020
Attributing income to the PE, under the DTAA - The income to the foreign branch from the credit given to its card holders outside India cannot be taxed in the hands of the Indian branch since it has not arisen in India and also it cannot be attributed to the assets and activities of the Indian branch, as is required by Article 7 of the DTAA. - AT
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