Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights September 2023 Year 2023 This

Income taxable in India - Existence of Permanent establishment ...

Income Tax

September 14, 2023

Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services for inspection/optimization/erection/commissioning repair in India to other parties - AO/DRP is not justified in holding that assessee has used the premises of its associate company in India for rendering services to its clients. - AT

View Source

 


 

You may also like:

  1. Fees for technical service was liable to tax in India under section 44BB of the Act only if the appellant had Permanent Establishment ("PE") in India in the relevant...

  2. Determination of Permanent Establishment - Article 5 of Indo-Mauritius DTAA – GPI project – the assessee clearly has a PE in India during the relevant years - AT

  3. Article 8 of DTAA between India and Germany - Reference to DRP - Pooling/slot arrangements - Permanent Establishment (PE) - Feeder services - operation of ships in...

  4. Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

  5. Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

  6. Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

  7. Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

  8. Fees for Technical Services – AO only undertook the issue of stay of technicians in India cannot be considered for examining the 'permanent establishment' of assessee in...

  9. The Indian Liaison Office involves a “Permanent Establishment‟ for the applicant under Article 5.1 of the DTAA with USA - income attributable to Liaison office is...

  10. Accrual of income in India - FTS - Existence of a PE - Determining income on presumptive basis attributable towards Permanent Establishment ("PE" ) - Tax Authorities...

 

Quick Updates:Latest Updates