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2 results for “section 68”+ Section 234B(3)clear

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Section 260A3

Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

ITTA/667/2014HC Telangana29 Jan 2015
Section 143(3)Section 147Section 260A

234B of the Act and consequently, the same is not being considered. 35. The first three questions framed in the aforesaid appeals relate to the dispute whether the Assessee has a PE in India and the fourth question relates to the issue of attribution of income to the Assessee‘s alleged PE in India. ITA 666/2014 & Ors. Page

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

ITTA/621/2017HC Telangana23 Aug 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 260A

3) which deals with only fixed place PE. It is indeed correct that neither a dependent agent PE nor a fixed place PE can be constituted if the business activities undertaken are preparatory or auxiliary. However, Article 5(3) makes no mention of the authority to conclude contracts – language that is explicitly used in Article 5(4)(a). Accordingly, reading