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Consideration towards supply of embedded software treated as consideration for supply of goods and not royalty
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International Tax
Consideration towards supply of embedded software treated as consideration for supply of goods and not royalty
Posted on
on
January 22, 2020
Tenet Tax Daily January 15 2020
By
tenettax-team
International Tax
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Provision of BPO services does not create service PE and hence not taxable as per DTAA.
No ‘Agency PE’ of assessee in India if Indian subsidiary did not conclude contracts on behalf of assessee-US company
