Home / 
Permanent Establishment in India Not Solely Determined by Mutual Agreement Procedure; MAP Not a Primary Basis.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Existence of PE in India - Mutual Agreement Procedure - The MAP procedure and agreement, is no doubt relevant but cannot be determinative or the primary basis to decide whether the assessee had PE in India. - HC....