Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
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Remote troubleshooting and maintenance did not create a fixed place PE, because the customers' systems were not at the assessee's disposal and the recognised tests of permanence and carrying on business through an identified place in India were not met. Site visits of 67 days also fell below the India-Canada DTAA threshold, and the treaty did not recognise a virtual service PE based only on remote service delivery. The tribunal further declined to treat a LinkedIn profile as determinative of employment status. No fixed place PE, service PE or supervisory PE existed, so the appeal was allowed and profit attribution was not examined.
Remote troubleshooting and maintenance did not create a fixed place PE, because the customers' systems were not at the assessee's disposal and the recognised tests of permanence and carrying on business through an identified place in India were not met. Site visits of 67 days also fell below the India-Canada DTAA threshold, and the treaty did not recognise a virtual service PE based only on remote service delivery. The tribunal further declined to treat a LinkedIn profile as determinative of employment status. No fixed place PE, service PE or supervisory PE existed, so the appeal was allowed and profit attribution was not examined.
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