Income Deemed to Accrue or Arise in India ::
Last updated: 07 September 2007
Court :
Tribunal
Brief :
Held that since the subsidiary co. did not have the authority to negotiate or enter into contracts on behalf of the foreign principal, it could not be held to be Permanent Establishment of the foreign co. in India and since, assessee did not have any PE in india, no income can be deemed to accrue or arise in India.
Citation :
Rolls Royce Pl. Vs. Asstt. Dir. I.T.
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CA.Saibaburao Nanduri
Published in Income Tax
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