profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise ... permanent establishment" includes profits arising from transactions in which the permanent establishment has been involved and such profits shall be regarded as attributable
effectively connected' to the permanent
establishment since for the said contract the assessee has
created a permanent establishment in India in the current year ... appellant's Indian permanent establishment. He submitted
that the functions performed by the Permanent establishment
stated at para No. 4.4 wherein in para
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
permanent
establishment. In other words, if the State where the permanent
establishment is located attempts to tax profits that are not
attributable to the permanent ... enterprise of which it is a permanent
establishment.
[3. In determining the profits of a permanent establishment, there
shall be allowed as deductions expenses which
