What is the crux of decision of ABB-FZZ ruling rendered by Bangalore ITAT?
What is the crux of decision of ABB-FZZ ruling rendered by Bangalore ITAT?
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What is the crux of decision of ABB-FZZ ruling rendered by Bangalore ITAT?
What is the crux of decision of ABB-FZZ ruling rendered by Bangalore ITAT?
The consequence of this judgement is that if foreign entity rendered services in India for any period more than the threshold period specified in DTAA, then it will constitute Service PE in India irrespective of existence of employees in India. Such a judgement by ITAT will have far reaching impact. As a consequence of such a judgement, tax authorities may start taxing Foreign enterprises for services rendered in India for a period beyond stated in respective DTAA.
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