Expat Director's Presence in India Insufficient to Establish Permanent Establishment for Income Tax Purposes.

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....Accrual of income - Permanent Establishment (PE)/Service PE/ Supervisory PE - There is no evidence of doing work by the Director in India in market research and related jobs. Merely because of the fact that expatriate Director was present in India, no nexus can be held to be established between HO and BO.....