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Project Office won’t be constituted as PE if Co. wasn’t carrying out its core business through it: SC

July 23, 2020[2020] 117 taxmann.com 870 (SC)/[2020] 272 Taxman 377 (SC)
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INTERNATIONAL TAXATION : Where assessee, a Korean company, was awarded a project by ONGC for purpose of surveys, design, etc., in view of fact that assessee was not carrying on its core business through its Project Office in India, said Project Office would not constitute permanent establishment within meaning of article 5(1) of DTAA between India and Korea

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