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Indian Subsidiary Co. not an agency PE if it had no authority to conclude contract on behalf of Foreign parent Co.

October 3, 2019[2019] 109 taxmann.com 99 (Mumbai - Trib.)

INTERNATIONAL TAXATION: Where Indian subsidiary company neither concluded any contracts on behalf of assessee-US company since it had no such authority nor secured any orders for it in India, it could not be regarded as 'Agency PE' of assessee in India

INTERNATIONAL TAXATION: Where two former diamond graders of assessee-US company were currently employed with Indian subsidiary company and were on payrolls and supervisions of Indian subsidiary, said employees did not create service PE of assessee in India

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