Search Results for Tag : permanent establishment

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ITAT, Delhi Deletes Penalty Against Lahmeyer Holding GambH(12.04.2022)

Income Tax Appellate Tribunal , Delhi has granted relief to Lahmeyer holding that the penalty cannot be levied based on fact that the assessee under s.....

Tags : Income Tax Appellate Tribunal, Lahmeyer Holding GambH, section 44BBB of the Income Tax Act, 1961, permanent establishment, bonafide

Del. HC: Samsung India Electronics is Not Samsung Korea’s Permanent Establishment in India(17.01.2025)

Delhi High Court has held that Samsung India Electronics Pvt. Ltd is not exigible to tax in India as it is not a 'Permanent Establishment' of South Ko.....

Tags : Delhi High Court, Samsung India, Permanent Establishment

Del. HC: Whether an Entity is a Permanent Establishment of Foreign Company is a Fact Specific Issue(20.01.2025)

Delhi High Court has held that the position of a Permanent Establishment of Foreign Company being a facts-specific issue is liable to be examined agai.....

Tags : Delhi High Court, Permanent Establishment, Foreign Company

Del. HC: Company’s Subsidiary Doesn’t Ipso Facto Constitute its Permanent Establishment(27.02.2025)

Del. HC has held that there is no general presumption in law that a subsidiary can never be acknowledged to be a Permanent Establishment (PE). This is.....

Tags : Delhi High Court, Permanent Establishment, Double Taxation Treaty

SC: Foreign Entity Liable to Pay Tax Solely on Basis of Permanent Establishment(25.07.2025)

Supreme Court has held that a foreign entity can be subject to tax liability in India based solely on the existence of a Permanent Establishment (PE),.....

Tags : Supreme Court, Permanent Establishment, Foreign Entity