Income deemed to accrue or arise in India - Revenue has failed ...
Revenue Authorities Fail to Prove Software Income Linked to Permanent Establishment in India.
August 29, 2023
Case Laws Income Tax AT
Income deemed to accrue or arise in India - Revenue has failed to establish on record through credible evidence that the assessee has a fixed placed PE in India through which it has earned the income relating to sale of software licence. Therefore, in our considered opinion, no part of such income can be attributed to the PE - AT
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