been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
been the admitted position between the parties that IMG had a
Service PE as contemplated under Article 5(2)(k) of the DTAA ... relevant AYs'. The attribution of income to the PE was explained
5
BCCI
6
Act
7
DTAA
8
PE
Signature Not Verified
Digitally Signed
CBDT NOTIFICATION DATED 03 17-21
NOVEMBER 2014
E. THE PE ISSUE- A BRIEF 22-30
BACKGROUND
F. THE CHALLENGE OF PROGRESS RAIL ... AUTHORITY'S RESPONSE 57-65
H. PE- A BROAD OVERVIEW 66-72
I. RESPONDENTS' TAKE ON PE- A 73-77
RECAP
J. ANALYSING
