Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of the assessee, finding that the business model post-2005 did not create a Permanent Establishment (PE) or an Agency PE in India for Sabre GLBL Inc., as the operations and agreements post-2005 significantly differed from the earlier model. The Tribunal differentiated the current business operations from those evaluated in the case of Galileo International Inc., where a PE was established due to the presence of an intermediary.
Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of the assessee, finding that the business model post-2005 did not create a Permanent Establishment (PE) or an Agency PE in India for Sabre GLBL Inc., as the operations and agreements post-2005 significantly differed from the earlier model. The Tribunal differentiated the current business operations from those evaluated in the case of Galileo International Inc., where a PE was established due to the presence of an intermediary.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
