Therefore, the appellant claimed that it did not have a Permanent Establishment (PE)
in India and that its business income was not taxable under Article ... business connection under Section 9(1)(i) of the Act;
(ii) a PE under Article 5 of the DTAA;
(iii) royalties and fees for technical
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
Form 10F declaring that it does not have any
permanent establishment (hereafter PE) in India.
7. On 01.02.2023, the petitioner and SFDC India entered into ... taxable under the
Act as it did not have a PE in India. However, the AO did not accept
the same. The AO reasoned that
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
National Highway Authority Of India vs Unitech -Ncc (Jv) on 30 May, 2025
Author: C
owned
subsidiary of the assessee constituted a Dependent Agent
1
AY
2
PE
3
NIPL
Signature Not Verified
Digitally Signed ITA 785/2019 & other ... against
Nokia OY on the question of taxability, the existence of a PE and
attribution of income. The adverse findings so returned
bare reading of the Act
makes it clear that the Permanent
Establishment (PE) of an
enterprise has been deemed to be
an Associated Enterprise ... there
is a deeming fiction created by
the law which makes a PE of an
enterprise as a separate legal
person (AE) by introducing such
