Assistant Director Of Income Tax vs E-Funds It Solution Inc.

Authority: Supreme Court Date: 2017-10-24 AY: 2000-01, 2001-02, 2002-03, 2003-04, 2004-05, 2005-06, 2006-07, 2007-08 Section: 5, 27, 90 Acts: Income Tax Act 1961, India-US Double Taxation Avoidance Agreement 1990 Result: Assessee Citation: (2017) 158 DTR (SC) 337 Justices: Judge(s) Rohinton Fali Nariman & Sanjay Kishan Kaul, JJ. Appeal No: Civil Appeal Nos. 6082, 6083, 6084, 6085, 6087 to 6097, 6099, 6100 to 6104
Whether the US-based assessee companies had a Permanent Establishment (PE) in India under Article 5 of the India-US DTAA, thereby making their income attributable to India taxable under the Income Tax Act 1961 --- Held No.

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