25 August 2010
If a Non Resident, in order to avoid repercussion of Sec 206AA, apply for PAN by quoting the address of a person residing in India in favour of whom he has issued a POA to sign his ROI, Does it amount to Agency PE?
26 August 2010
Obtaining of PAN under section 206AA is for the limited pupose of avoiding enhanced deduction of TDS on income likely to arise in India.Your merely authorising a person under GPA would be regarded as PE, if only any specific income, involving international business transactions are involved.
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