Permanent establishment definition broadened to include fixed place and contractual work, altering tax treatment of cross-border activities. The amendment expands clause (iii) to include activities 'in carrying out any work in pursuance of a contract,' inserts that permanent establishment includes a fixed place of business through which the enterprise's business is wholly or partly carried on, and substitutes the definition of specified date to mean the 'due date' as defined in Explanation 2 to sub section (1) of section 139, aligning timing and PE concepts within section 92F.
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Provisions expressly mentioned in the judgment/order text.
Permanent establishment definition broadened to include fixed place and contractual work, altering tax treatment of cross-border activities.
The amendment expands clause (iii) to include activities "in carrying out any work in pursuance of a contract," inserts that permanent establishment includes a fixed place of business through which the enterprise's business is wholly or partly carried on, and substitutes the definition of specified date to mean the "due date" as defined in Explanation 2 to sub section (1) of section 139, aligning timing and PE concepts within section 92F.
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