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Business support activities proposed by Indian subsidiary won’t create PE of its foreign holding Co.: AAR

June 14, 2018[2018] 94 194 (AAR - NewDelhi)/[2018] 405 ITR 83 (AAR - NewDelhi)/[2018] 303 CTR 225 (AAR - NewDelhi)

IT/ILT : Business support/marketing support activities proposed to be undertaken by Indian affiliate entity would not create a Permanent Establishment of Saudi Arabian company in India engaged in offshore sale of oil outside India if such activities are duly compensated on an arm's length basis

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