treaty on the basis that it was not having any permanent establishment (PE) in India during the year under consideration. Besides the supply of engineering ... Asia Ltd. and UOP India (P) Ltd. were working as dependent agent PE of the assessee in India within the meaning given in para
made while computing the profits attributable to a PE under the old India-France tax treaty [(1970) 76 ITR (St.) 1]. In thefirst order ... deduct income-tax thereon at the rates in force." The Branch/PE of the assessee in India is not a person in legal terminology
prepared by Sh. Manmohan Mehra/ Sh.
Anupam N ag alia for the pe rusal o f Sh. Gautam Bhalla. The heading
of this document ... similar purchase price and sale
price .
Q. 33 As pe r the 1st agreement to sell be tween M/s S E H Realto
India on the basis that the appellant has a
Permanent Establishment ("PE") in India under the
provisions of Article 5 of the Double ... auxiliary in nature
and therefore not excluded from the purview of
constituting PE under Article 5(4)(e) of the India-
Finland tax treaty
pe ... acte d in re s pe ct
of the cre d its , c as h , e x pe
during the year under consideration it had not
constituted a Permanent Establishment (PE) in India within the meaning
of Article 5 of the India-Singapore ... mineral oils in a contracting state, for the
purpose of constituting a PE in that contracting state, during any fiscal
year. In sum and substance
expatriate employees working in India
exclusively for the permanent establishment ('PE') of
the Appellant, is fully allo wed as deduction under
section ... accrued/ received
by the Indian Permanent Establishment ('PE') from its
HO/ overseas branches.
2.1 That on the facts and in the circumstances
financial year
relevant to the a ssessment year 2005-06. As pe r
schedule -3 assessee has received amount ... State Government's
Account and Rs.1,99 ,26,154 pe rtained to General
Development Account i.e. the Appellant
taxable in India, only if it has a Permanent Establishment (PE) in India and
in such case only to the extent of profits that ... attributable to the PE in
India. The assessee further claimed that for the year ended 31.03.2012 it
has no PE in India as contemplated under
International Inc.
In the return of income, the income attributable to such PE is not
disclosed.
4. The assessee has set up an equipment ... assessee, through which its business is
being carried on. Accordingly, assessee has PE as per the provisions of paragraph 1 of Article
