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Permanent Establishment

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Jyoti P. Nayak

Jyoti P. Nayak (Querist)
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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?

venkatraman shrinivas

venkatraman shrinivas (Expert)
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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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