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Articles 5 and 7 of the DTAA :
"Article 5
PERMANENT ESTABLISHMENT
1. For the purposes of this Convention, the
term ... permanent establishment" means a
fixed place of business through which the
business of an enterprise wholly or partly
carried
Supreme Court of India
payment of salaries was not borne by the permanent establishment in
India and so the employee in question would ... Elitos S.P.A. did not have a permanent
establishment or fixed base in India. The Income Tax Officer
Allahabad High Court
phrase "directly
or indirectly attributable to that permanent
establishment" employed in paragraph 1 of article 7.
Further, profits shall also ... regarded as attributable to
the permanent establishment to the extent indicated in the
said protocol even when the contract
Supreme Court of India
Department concern computation of the
profits of the Indian permanent establishment (for short, "PE") of the
Korean company ... business in the other Contracting State through a permanent
establishment situated therein. If the enterprise carries on business as
aforesaid
Supreme Court of India
necessary that the deduction for expenses attributable to a
permanent establishment incurred either in the country where the
permanent establishment ... been provided that deduction for expenses attributable
to a permanent establishment would be allowable only to the extent such
expenses
Income Tax Appellate Tribunal - Mumbai
Fiscal
Evasion of Tax unless the respondent has a permanent establishment of
the business in India such business income ... held that (i)
since the respondent has no permanent establishment for business in
India, the business income in Malaysia cannot
Supreme Court of India
work carried in
India and therefore attributable to permanent establishment which
was not relevant for the interpretation and applicability ... business
in the other contracting State through a permanent establishment
therein, there shall in each contracting State be attributed
Income Tax Appellate Tribunal - Delhi
resident carried on
business in India through a permanent establishment (PE) and to the
extent the profits are attributable ... permanent establishment of
such US resident. The applicant submits that BRI could have been
construed to have a permanent establishment
Authority Tribunal
also observed that if the
assessee had no permanent establishment in India, there could be no
question of carrying ... Income-tax Officer that if there was no
permanent establishment of the assessee in India, there could be no
question
Income Tax Appellate Tribunal - Mumbai
were not borne by the permanent establishment and,
therefore, were not claimed as expenses in India. The other major
expenses ... Double
Taxation Avoidance Agreement provides that taxation of a permanent
establishment of a Contracting State shall not be less favourably
Bombay High Court
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