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Question of existence of PE can’t be foreseen at stage of deciding application for issue of certificate u/s 197

December 27, 2019[2019] 112 364 (Delhi)/[2020] 271 Taxman 150 (Delhi)/[2020] 421 ITR 24 (Delhi)

INTERNATIONAL TAXATION : Question of existence of Permanent Establishment (PE), of an assessee in India which requires a detailed enquiry, is not envisaged at stage of deciding application for issuance of certificate under section 197

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