2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
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Mumbai ITAT Tekmark GlobalSolutions LLC• Indo-US Treaty : Persons deputed by an American<strong>Com</strong>pany to an Indian company cannot be considered asits PE in India when services rendered by them areindependent and not under control of that Americancompany• No income would arise to the American company in Indiain the course of deputing personnel to an Indian companywho work under the control and supervision of the Indiancompany and carry out the work allotted to them by theIndian <strong>Com</strong>pany and the American company isreimbursed by the Indian company