Friday: 10.30 pm, Saturday: 11.30 am
Sunday: 9:30am & 11.00pm
Published on Thu, Apr 24,2014 | 19:54, Updated at Thu, Apr 24 at 19:54Source : Moneycontrol.com
This PwC News Alert summarizes the recent decision of Renoir Consulting Limited, wherein the Mumbai Income-tax Appellate Tribunal (Tribunal) has analysed the emergence of a Permanent Establishment (PE) for a foreign company by virtue of rendering certain services to its Indian customers. The Tribunal held that the foreign company constituted a PE through the hotel rooms used by its personnel when in India, notwithstanding the fact that the location of the top management was based outside India. On attribution, the Tribunal principally upheld the allowability of expenditure on the basis that beneficial provisions of the tax treaty would supersede provisions of the domestic law.
The significance of this Alert is to establishments where International Workers are deputed/ employed.
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