IT/ILT : Where five Finnish engineers though belonging to a Finnish entity do not represent that entity in rendering supervisory services by the engineers for erection, commissioning of the plant in India and there is no agreement between the Indian Entity and the Finnish entity, the tests of taxability of IPS in Art 15(1)(a)(90 days or more presence in India in fiscal year and Art 15(1)(b)(fixed base regularly available to him in India) should be applied to each engineer individually. The perio
No comments:
Post a Comment