https://www.taxtmi.com/highlights?id=67155 PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that the issue of taxability would arise qua the respondent/assessee only if profits accrue to the respondent/assessee, and that too only to the extent they can be attributed to its PE in India. - HC en-us Fri, 16 Dec 2022 13:19:38 +0530 Fri, 16 Dec 2022 13:19:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=67155 PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that the issue of taxability would arise qua the respondent/assessee only if profits accrue to the respondent/assessee, and that too only to the extent they can be attributed to its PE in India. - HC Highlights Income Tax Fri, 16 Dec 2022 13:19:38 +0530 https://www.taxtmi.com/highlights?id=67155