TDS u/s 195 - profit attributable to the PE in India - the ...

Income Tax

September 28, 2022

TDS u/s 195 - profit attributable to the PE in India - the privity of contract is between the assessee and Indian customers, wherein, CCPL has no role to play. The aforesaid factual position emerging on record could not be effectively controverted by the Revenue through proper evidence. - the assessee cannot be construed as a dependent agent PE of CCPL - CIT(A) rightly deleted the additions - AT

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TDS u/s 195 - profit attributable to the PE in India - the ...

Income Tax

September 28, 2022

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