https://www.taxtmi.com/circulars?id=2862 A non resident is taxable in India only if an Indian IT enabled BPO unit constitutes its Permanent Establishment; where a Permanent Establishment exists, profits attributable to it must be determined under Article 7 by attributing the profits the establishment would have earned as a separate enterprise, applying the arms length principle and allowing deductible expenses in accordance with accepted accounting principles and the Income tax Act; arms length price is as defined in section 92F(iii) and sections 92-92F apply. The earlier CBDT Circular No.1/2004 is withdrawn. en-us Tue, 28 Sep 2004 00:00:00 +0530 Mon, 11 Aug 2008 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=2862 A non resident is taxable in India only if an Indian IT enabled BPO unit constitutes its Permanent Establishment; where a Permanent Establishment exists, profits attributable to it must be determined under Article 7 by attributing the profits the establishment would have earned as a separate enterprise, applying the arms length principle and allowing deductible expenses in accordance with accepted accounting principles and the Income tax Act; arms length price is as defined in section 92F(iii) and sections 92-92F apply. The earlier CBDT Circular No.1/2004 is withdrawn. Circulars Income Tax Tue, 28 Sep 2004 00:00:00 +0530 https://www.taxtmi.com/circulars?id=2862