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No agency PE under India-France DTAA even if agent is wholly dependent on foreign Co. unless transaction isn’t at ALP

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  • No agency PE under India-France DTAA even if agent is wholly dependent on foreign Co. unless transaction isn’t at ALP
Posted onon April 28, 2015

Tenet Tax Daily April 28 2015

By tenettax-team
International Tax

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TP adjustment is to be made only in respect of purchases made from AE and not from unrelated parties
No TDS on sum paid for extra cost incurred by contractor due to delay in completion of work by sub-contractor

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