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No ‘Agency PE’ of assessee in India if Indian subsidiary did not conclude contracts on behalf of assessee-US company
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International Tax
No ‘Agency PE’ of assessee in India if Indian subsidiary did not conclude contracts on behalf of assessee-US company
Posted on
on
January 22, 2020
Tenet Tax Daily January 16 2020
By
tenettax-team
International Tax
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Consideration towards supply of embedded software treated as consideration for supply of goods and not royalty
Absolute owner of Compulsorily Convertible Debentures (CCDs) receiving interest income would be entitled to beneficial provisions of article 11 of DTAA between India and Cyprus
