https://www.taxtmi.com/caselaws?id=33860 AAR held that under the contract the sale of equipment and materials occurred outside India, so the related income did not accrue or arise in India and was not taxable under the IT Act or the India-Korea DTAA. The applicant was also found not to constitute a PE under Art. 5.3 of the DTAA on the presented facts. The question of PE was nevertheless left open to the AO for further inquiry. en-us Wed, 17 Jun 2009 00:00:00 +0530 Mon, 17 Nov 2025 14:59:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33860 AAR held that under the contract the sale of equipment and materials occurred outside India, so the related income did not accrue or arise in India and was not taxable under the IT Act or the India-Korea DTAA. The applicant was also found not to constitute a PE under Art. 5.3 of the DTAA on the presented facts. The question of PE was nevertheless left open to the AO for further inquiry. Case-Laws Income Tax Wed, 17 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33860