Mere presence of personnel of a foreign holding in premises of Indian subsidiary to render services cannot constitute PE in India – JSCO | SITG
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Mere presence of personnel of a foreign holding in premises of Indian subsidiary to render services cannot constitute, either fixed place or supervisory PE of foreign company. FCC Co. Ltd. vs. ACIT [ITA Nos. 8960 & 54/Del/2019 ]