Swiss Affiliate (EXP-IN) Not a DAPE; Business Profits Not Taxable in India, Reassessment Sanctions Held Valid
Swiss Affiliate (EXP-IN) Not a DAPE; Business Profits Not Taxable in India, Reassessment Sanctions Held Valid Issues Agency Permanent Establishment (DAPE): Whether the Swiss assessee’s Indian affiliate (EXP-IN) constituted a Dependent Agent Permanent Establishment (DAPE) in India under Article 5(5) of the India–Switzerland DTAA, making its revenue taxable in India. Validity of Reassessment Sanction: Whether… Read More »