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Sister concern of Foreign Co. rendering services in India under independent contracts couldn't be held as PE

December 30, 2019[2019] 112 219 (Delhi - Trib.)

INTERNATIONAL TAXATION : Where assessee, an Italy based company, supplied microwave transmission equipments to Indian companies whereas activities of installation, commissioning and maintenance of those equipments were carried out by assessee's sister concern in India under independent contracts and income from those activities were duly offered to tax, said sister concern could not be regarded as assessee's PE in India in terms of article 5 of India-Italy DTAA

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