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Fixed PE established if Indian subsidiary securing business for Singaporean Co. by entering into agreements

July 23, 2020[2020] 117 taxmann.com 756 (Mumbai - Trib.)/[2020] 183 ITD 832 (Mumbai - Trib.)
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International Taxation : Where assessee, a Singapore based company, was engaged in business of promotion, development, marketing and maintenance of Computerized Reservation System (CRS) for airlines, had its wholly owned subsidiary in India which was exclusively performing marketing and distribution of CRS and was also securing business for assessee by entering into subscription agreement with various travel agents, it could be regarded as assessee's fixed PE in India

Transfer Pricing : Addition to ALP in respect of notional interest on interest free loan given to Indian subsidiary was to be confirmed taking rate of LIBOR plus 2 per cent

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