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Income Tax - Highlights / Catch Notes

Home Highlights August 2023 Year 2023 This

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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