resident assessee carries
out its business in India through a Permanent Establishment (PE)
situated therein and the right, property or contract in respect of
which ... services, where such nonresident carries on business in India
through a permanent establishment situated therein or performs
services from a fixed place of profession situated
same cannot be taxed at all, in
the absence of any Permanent Establishment ('PE') of the Appellant in
India in terms ... which are not applicable in the absence of a Permanent
Establishment in India under India Canada DTAA especially in the light
of explanation
same cannot be taxed at all, in
the absence of any Permanent Establishment ('PE') of the Appellant in
India in terms ... which are not applicable in the absence of a Permanent
Establishment in India under India Canada DTAA especially in the light
of explanation
same cannot be taxed at all, in
the absence of any Permanent Establishment ('PE') of the Appellant in
India in terms ... which are not applicable in the absence of a Permanent
Establishment in India under India Canada DTAA especially in the light
of explanation
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
group
company in India. Hence, the assessee does not constitute a Permanent
Establishment (PE) in India. In absence of a PE of the assessee ... constitutes a
ITA No. 216 & Ors.
Sabre GLBL Inc.
4
permanent establishment (PE) in India and attributing total profits earned from
booking fee originating
