exams at all levels in the last 2 years
(i.e. PE1/PE2/PCC/CPE/Final with break up)
8) Number of students ... number of students that failed in the last 2 years (i.e.
PE1/PE2/PCC/CPE/Final with break up) from the above
sought was two fold namely, whether the
applicant was having a PE in India under Article 5(1) of the
DTAA on account ... applicant and if so, the amount of income attributable
to such PE.
5. By the impugned ruling delivered on 13.2.2006 by the
Authority for Advance
Date of Decision: 29.05.2023
Madhu Tanwar and Anr ...Pe oners
Versus
State of Punjab ...Respondent
CORAM: HON'BLE MR. JUSTICE ANOOP CHITKARA
Present ... Abhimanyu Singh, Advocate for the pe oners.
Mr. Harsimar Singh Si'a, DAG, Punjab.
Mr. Surender Pal, Advocte for the complainant.
****
ANOOP CHITKARA
computation of the
profits of the Indian permanent establishment (for short, "PE") of the
Korean company, M/s .Hyundai Heavy Industries ... assesses stated that it did not have a PE in India and, therefore, it was
not assessable to tax in India; that its Indian Operations
India?; and
(ii) whether FOWC was having any 'Permanent Establishment' (PE) in India
in terms of Article 5 of DTAA?
Another related question ... answered in favour of FOWC holding that it did not have any PE
in India. As far as the question of subjecting the payments
Kyin and his wife obtained payment of this sum from U Shwe Pe and his wife, and conveyed the properties ... March, 1903, Kyin and his wife transferred these properties to Shwe Pe and his wife in consideration of a payment of 11,000 rupees
private equity firm are the highest paid,
therefore, the profit in the PE business are the highest. He further submitted that
combining results ... PE advisory job with the financial result of merchant
banking activity (with low profit margin) would result in profit margin of total
entity getting reduced
Class, Kurukshetra (PW6)
recorded the statement of deceased Manjit Kaur (Ex. PE) on
24th April 1998, wherein she stated that her husband had
demanded ... lakhs to go to USA. According to the said
dying declaration (Ex. PE), the appellant as well as his
parents administered the said poisonous substance
Rule 3.16 of the
Vigilance Manual, 2008 dealing with the Preliminary Enquiry (PE) being
Signature Not Verified
in direct conflict with the Constitution Bench Judgment ... declared Rule 3.16 of the Vigilance Manual, 2008
dealing with Preliminary Enquiry (PE) as ultra vires on the ground that
the same is in direct
Officer (AO) found that the assessees had a permanent establishment ("PE")
in India. The taxable income of the assessees was computed by attributing ... some percentage of the sale price/consideration received as profits to the PE;
interest under Sections 234A and 234B of the Act was also levied
