Indian VIPL Not a Dependent Agent or PE for Varian Companies, No Tax on 10% Sales Addition Under Article 5 DTAAs.

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....The Indian branch of the VIPL is not dependent agent of VGCs and therefore, it does not constitute PE for various Varian companies in India, as per Article 5(4) 5(5), respective DTAAs. - the addition being 10% of gross sales made by Varian Italy to its customer in India, cannot be taxed in the hands of the assessee. - AT....