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

July 23, 2020[2020] 117 756 (Mumbai - Trib.)

INTERNATIONAL TAXATION : Where assessee, a Singapore based company, was engaged in business of promotion, development, marketing and maintenance of Computerized Reservation System (CRS), 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 : Following order passed by Co-ordinate Bench of Tribunal in assessee's own case in earlier assessment year, addition to ALP in respect of notional interest on interest free loan given to Indian subsidiary was to be confirmed at rate of LIBOR plus 2 percent

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