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Re-assessment affirmed as commission paid to foreign agent was included in cost of asset to escape TDS liability
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Corporate Tax
Re-assessment affirmed as commission paid to foreign agent was included in cost of asset to escape TDS liability
Posted on
on
September 17, 2014
Tenet Tax Daily September 17 2014
By
tenettax-team
Corporate Tax
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Broker assuming all risks without any right to conclude contracts on behalf of NR can’t be treated as agency PE
Supervisory services without having control of physical sites couldn’t constitute a PE as per DTAA with Germany
