Indian-Singapore Tax Treaty: No Permanent Establishment Found in India, Business Profits Not Taxable Under Treaty Rules.

Indian-Singapore Tax Treaty: No Permanent Establishment Found in India, Business Profits Not Taxable Under Treaty Rules. https://www.taxtmi.com/highlights?id=68799 Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on record, we hold that the assessee does not have any PE in India. Therefore, in absence of PE, the business profits of the assessee cannot be taxed in India. Accordingly, the additions made by way of attribution of profit to the PE in India deserve to be deleted. - AT en-us Sat, 18 Mar 2023 12:13:19 +0530 Sat, 18 Mar 2023 12:13:19 +0530 TaxTMI RSS Generator Indian-Singapore Tax Treaty: No Permanent Establishment Found in India, Business Profits Not Taxable Under Treaty Rules. https://www.taxtmi.com/highlights?id=68799 Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on record, we hold that the assessee does not have any PE in India. Therefore, in absence of PE, the business profits of the assessee cannot be taxed in India. Accordingly, the additions made by way of attribution of profit to the PE in India deserve to be deleted. - AT Highlights Income Tax Sat, 18 Mar 2023 12:13:19 +0530 https://www.taxtmi.com/highlights?id=68799