Monday, 16 November 2015

HC considers actual usage of rig instead of it being ready for use to determine PE

IT/ILT : In order to determine question as to whether assessee owing rig had PE in India, Tribunal rightly concluded that unless rig owned by assessee was actually used for a period of 120 days in India, it would not be sufficient to attract article 5(2)(j) of India - USA DTAA

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