Audi AG's car sales to VW Group aren't a Permanent Establishment u/s 9, Indo-Germany Tax Treaty Article 5.

Audi AG's car sales to VW Group aren't a Permanent Establishment u/s 9, Indo-Germany Tax Treaty Article 5. https://www.taxtmi.com/highlights?id=49620 Permanent Establishment - Car is manufactured by the Audi AG outside India and constitutes a separate and independent activity. As noted earlier the car is sold to VW Group for further sale in India and VW Group sale is not acting on behalf of Audi AG nor is Audi AG selling cars through VW Group sales. - AO was not justified in invoking section 9 of the Act and the Article 5 of Indo-Germany Tax Treaty for taking view that assessee has PE in India. en-us Fri, 04 Oct 2019 10:52:54 +0530 Fri, 04 Oct 2019 10:52:54 +0530 TaxTMI RSS Generator Audi AG's car sales to VW Group aren't a Permanent Establishment u/s 9, Indo-Germany Tax Treaty Article 5. https://www.taxtmi.com/highlights?id=49620 Permanent Establishment - Car is manufactured by the Audi AG outside India and constitutes a separate and independent activity. As noted earlier the car is sold to VW Group for further sale in India and VW Group sale is not acting on behalf of Audi AG nor is Audi AG selling cars through VW Group sales. - AO was not justified in invoking section 9 of the Act and the Article 5 of Indo-Germany Tax Treaty for taking view that assessee has PE in India. Highlights Income Tax Fri, 04 Oct 2019 10:52:54 +0530 https://www.taxtmi.com/highlights?id=49620