4 results for “transfer pricing”+ Permanent Establishmentclear
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In the result, all these three appeals of the Revenue are dismissed
Bench: Shri Pawan Singh & Dr. Arjun Lal Saini
permanent establishment in India and therefore, no income accrue or arise or deem to arise in India in terms of section 9(1)(i) of the Act. Such income is not chargeable to tax India as per section 195 of the Act. The learned CIT(A) following the decision of honorable Supreme Court in CIT versus Toshoku Limited (supra) deleted