https://www.taxtmi.com/highlights?id=15521 Indo French DTAA - PE - Since there are no findings by the A.O., or the DRP, to the effect that the transactions between the agent and the assessee are not at an arm's length price, the agent is treated to be an independent agent in view of the provisions of Article 5(6). Such a finding by the revenue is a sine qua non for existence of PE - AT en-us Mon, 04 Nov 2013 06:36:40 +0530 Mon, 04 Nov 2013 06:36:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=15521 Indo French DTAA - PE - Since there are no findings by the A.O., or the DRP, to the effect that the transactions between the agent and the assessee are not at an arm's length price, the agent is treated to be an independent agent in view of the provisions of Article 5(6). Such a finding by the revenue is a sine qua non for existence of PE - AT Highlights Income Tax Mon, 04 Nov 2013 06:36:40 +0530 https://www.taxtmi.com/highlights?id=15521