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Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Sample Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Sample Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Sample Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Sample Activity related or incidental but not carried out at site in source country is not to be construed as a PE
Commissioner of Income-tax, International Taxation-1 v. Bellsea Ltd
15-11-2022
IT APPEAL NOS. 90 OF 2019 & 357 OF 2022
Practiceguru Sample Posters - Pl Subscribe
Clause (g) of Article 5(2) of India Cyprus Treaty ostensibly refers to activity based PE, because the main emphasis is on "where such site project or activity continues for a period of more than 12 months".
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
On the facts and material on record and in view of reasoning given which is in consonance and in line with the principle laid down in the Hon'ble Jurisdictional High Court, it was held that threshold period of 12 months have not exceeded in the present case and consequently no PE can be said to have been established in Article 5(2)(g).
Accordingly, it was held that no income of the assessee on the Contract executed by assessee in India can be held to be taxable in terms of Article 7.
Practiceguru Sample Posters - Pl Subscribe
Sample 