Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory re...
Page of 4891
Press 'Enter' after typing page number.
61 to 80 of 97820 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Fixed place permanent establishment requires evidence that the...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore supplies.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for its business; group-wide Form 10-K and website material do not establish that condition. A subsidiary relationship alone is insufficient. Dependent agency permanent establishment also requires authority to conclude contracts or habitual order securing for the foreign enterprise. Independent principal-to-principal dealings, the subsidiary's separate manufacturing operations, and a licence arrangement confined to royalty-bearing products did not satisfy those conditions. Neither form of permanent establishment arose, so no Indian profits were attributable to the disputed offshore supplies and the attribution was deleted.
Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for its business; group-wide Form 10-K and website material do not establish that condition. A subsidiary relationship alone is insufficient. Dependent agency permanent establishment also requires authority to conclude contracts or habitual order securing for the foreign enterprise. Independent principal-to-principal dealings, the subsidiary's separate manufacturing operations, and a licence arrangement confined to royalty-bearing products did not satisfy those conditions. Neither form of permanent establishment arose, so no Indian profits were attributable to the disputed offshore supplies and the attribution was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
