service agent) to the tune of
Rs.40,78,10,733/- under Article 13 of the India-France Tax Treaty. We find
that the Tribunal ... assessee to Singapore Branch to the tune of
Rs.325,963,282/- under Article 13 of the India-France treaty. We find that
while deciding
branch (service agent) to the tune of Rs 40.78 10,733/ under Article 13
of the India-France Tax Treaty. We find that the Tribunal ... assessee to
Singapore Branch to the tune of Rs 325,963,282/- under Article
13 of the India-France treaty. We find that while deciding
branch (service agent) to the tune of Rs 40.78 10,733/ under Article 13
of the India-France Tax Treaty. We find that the Tribunal ... assessee to Singapore Branch to the tune of Rs
325,963,282/- under Article 13 of the India-France treaty. We find that while
deciding
service agent) to the tune
of Rs.40,78,10,733/- under Article 13 of the India-France Tax Treaty.
We find that the Tribunal ... assessee
to Singapore Branch to the tune of Rs.325,963,282/- under
Article 13 of the India-France treaty. We find that while
deciding
branch (service agent) to the tune of Rs 40.78
10,733/ under Article 13 of the India-France Tax Treaty. We find that the
Tribunal ... assessee to Singapore Branch to the tune of Rs
325,963,282/- under Article 13 of the India-France treaty. We find that while
deciding
income of the
Appellant to the tune of Rs.325,963.282/- under Article 13 (Royalty and fees
for technical services) of the India-France ... assessee to Singapore Branch to
the tune of Rs.325,963,282/- under Article 13 of the India-France treaty.
We find that while deciding
limitations of domestic law in
computing profit under article 7 was implicit by the virtue of article 25(1) of the India UAE tax
treaty ... vide Notification No.282/2007 dated
28/11/2007 which is effective from 1st day of April-2008, paragraph 3 of Article 7
(Business Profits
Article 7(3) of the Treaty to
limit the expenditure to a particular percentage. Therefore, in
absence of any restrictions/conditions expressly provided in
Article ... notification no. SO 2001(E) (NO)
282/2007, dated 28.11.2007. In the said Protocol, the earlier
Article 7(3) was substituted by following
Government of UAE vide
Portfolio dated 15th June 2006, notified with No. 282 of 2007 dated 28th
November 2007 cannot be considered, at this stage ... notified vide Notification No.
282 of 2007 dated 28th November 2007. This Protocol amended the DTAA
and vide Article 4 of the Protocol the following
length compensation to the dependent agent enterprise under Article 9 (the following example is one where the dependent agent is an associated enterprise).
281. Assume ... found to exist under Article 5(5). There are two steps to the transfer pricing analysis.
282. Firstly, it is necessary to attribute
