Indian agents are the dependent agents. As for the plea that
in case the assessee is held to have a dependent agent permanent establishment ... permanent establishment under Article 5(1). As for
the permanent establishment under Article 5(2) , even by definition, there cannot be a
permanent establishment under
permanent establishment, when there is no establishment at all. It is, however, important to note that what is defined as a permanent agent ... facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing.
17. Learned Counsel has then relied
Indian agents are the dependent
agents. As for the plea that in case the assessee is held to have a dependent agent
permanent establishment ... permanent establishment under Article 5(1). As for the permanent establishment
under Article 5(2) , even by definition, there cannot be a permanent establishment
under
Indian agents are the dependent agents. As for
the plea that in case the assessee is held to have a dependent
agent permanent establishment ... permanent
establishment under Article 5(1). As for the permanent
establishment under Article 5(2) , even by definition, there cannot
be a permanent establishment under
Indian agents are the dependent
agents. As for the plea that in case the assessee is held to have a
dependent agent permanent establishment ... permanent establishment under Article 5(1). As for the permanent
establishment under Article 5(2) , even by definition, there cannot be
a permanent establishment under
Indian agents are the dependent agents. As for the plea that
in case the assessee is held to have a dependent agent permanent establishment ... permanent
establishment under Article 5(1). As for the permanent establishment under Article 5(2) , even
by definition, there cannot be a permanent establishment under
permanent establishment under Article 5(1). As for the permanent
establishment under Article 5(2) , even by definition, there cannot be a
permanent establishment under ... facts of the present case, that dependent agent and
dependent agent permanent establishment are one and the same thing.
17. Learned counsel has then relied
Article 5(2) , and in all these cases, the
permanent establishment is dependent agency permanent
establishment, i.e., under Article 5(4). Even the case ... 2023
A.Y. 2021-22
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agent and dependent agent permanent establishment are one and the
same thing.
17. Learned counsel
permanent establishment under
Article 5(1). As for the permanent establishment
under Article 5(2) , even by definition, there
cannot be a permanent establishment under ... facts of the present
case, that dependent agent and dependent agent
permanent establishment are one and the same thing.
17. Learned counsel has then relied
permanent establishment
under Article 5(1). As for the permanent establishment under Article 5(2) , even by
definition, there cannot be a permanent establishment under ... facts of the present case, that dependent agent
and dependent agent permanent establishment are one and the same thing.
17. Learned counsel has then relied
