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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 28, 2019[2019] 112 364 (Delhi)

INCOME TAX/INTERNATIONAL TAXATION : The question of existence of permanent establishment (PE) of a non-resident assessee, which requires a detailed enquiry is not envisaged at the stage of deciding the application for issuance of certificate under section 197. However, the full fledged investigation in said regard can be done by the Assessing Officer during the course of assessment proceedings

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