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Permanent establishment defined as fixed place or dependent agent authority creating taxable business presence under DTAA. Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, including places such as a place of management, branch, office, factory, workshop, extraction sites and warehouses. Construction or installation projects constitute a permanent establishment only if they last more than six months. Activities confined to storage, display, delivery, maintenance of stock for storage or processing by another, purchasing, information collection, or otherwise preparatory or auxiliary functions do not create a permanent establishment. An enterprise also has a permanent establishment where a non-independent agent habitually has authority to conclude contracts, whereas independent agents acting in their ordinary course do not create one.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment defined as fixed place or dependent agent authority creating taxable business presence under DTAA.
Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, including places such as a place of management, branch, office, factory, workshop, extraction sites and warehouses. Construction or installation projects constitute a permanent establishment only if they last more than six months. Activities confined to storage, display, delivery, maintenance of stock for storage or processing by another, purchasing, information collection, or otherwise preparatory or auxiliary functions do not create a permanent establishment. An enterprise also has a permanent establishment where a non-independent agent habitually has authority to conclude contracts, whereas independent agents acting in their ordinary course do not create one.
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