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1 - 7 of 7 (0.51 seconds)Article 12 in Constitution of India [Constitution]
Uae Exchange Centre Limited vs Union Of India And Another on 13 February, 2009
18. Further, our attention was drawn upon paragraph 2 to
the Commentary on Article 5 of the OECD Model Tax
Convention to argue that even where a fixed place of
business satisfies the activity test, but if the activities of the
BO are of a preparatory or auxiliary character, then it would
not constitute PE. In this regard, reliance was placed on the
judgment of Hon'ble Delhi High Court in U.A.E. Exchange
Centre Ltd. v. Union of India (313 ITR 94).
M/S Dit (International Taxation), ... vs M/S Morgan Stanley & Co. Inc on 9 July, 2007
Similar principles
were applied by the Supreme Court in the case of DIT v.
Morgan Stanley (292 ITR 416), by the Authority for Advance
Rulings in KT Corporation (181 Taxman 94) and by the
Mumbai ITAT in Dy. DIT v. Staubli A.G. India Branch Office
(40 SOT 14).
Article 7 in Constitution of India [Constitution]
The Income Tax Act, 1961
Jebon Corporation vs The Commissioner Of Income-Tax on 8 February, 2011
In this regard,
reliance was placed on the ruling of the Bangalore ITAT in
the case of Dy. DIT v. Jebon Corporation India Liaison Office
(125 ITD 340) and upheld by the Karnataka High Court (HC) in
Jebon Corporation India v. CIT (19 taxmann.com 119);
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