Search Results for "permanent establishment"

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High Court

High Court Dismisses Writ Petition in Income Tax Matter Involving India-China DTAA Interpretation. Petitioner's Claim for NIL Withholding Tax Certificate Rejected Due to Pending Assessments and Previous Tax Determinations Under Section 197 of Income Tax Act, 1961.

27 Mar 2026

The dispute involved a Chinese company, Petitioner, which provided technical services to its Indian subsidiary, Benteler India Private Limited, under ...

Supreme Court

Supreme Court Quashes ITAT Order Recalling Its Earlier Order Under Section 254(2) of Income Tax Act — Powers Limited to Rectification of Mistake Apparent from Record. The ITAT cannot re-hear the entire appeal on merits under the guise of rectification; the remedy against an erroneous order lies in appeal before the High Court.

3 Dec 2021

The case involves appeals by the Revenue against a common judgment of the Bombay High Court, which dismissed writ petitions challenging an order of th...

Supreme Court

Supreme Court Dismisses Department's Appeal in Permanent Establishment Tax Dispute Under India-Korea DTAA. Court Upholds ITAT's Finding of Permanent Establishment but Remands Profit Attribution for Fresh Assessment Due to Insufficient Material.

22 Jul 2020

The dispute arose from the taxability of income attributable to a permanent establishment set up in India by Samsung Heavy Industries Co. Ltd., a Sout...

Supreme Court

Supreme Court Upholds Tax Liability on Liaison Office Activities in India Under Income Tax Act, 1961 and DTAA. Income from printing and dispatching cheques in India through liaison offices constitutes business connection and permanent establishment, making profits attributable to such activities taxable in India.

24 Apr 2020

The respondent, U.A.E. Exchange Centre, a company incorporated in the United Arab Emirates, provided remittance services for transferring amounts from...

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