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HC set-aside ITAT’s order justifying levy of 65% tax rate on PE of Japanese Co. in India

August 20, 2019[2019] 108 taxmann.com 242 (Calcutta)
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INTERNATIONAL TAXATION: By virtue of article 24(2) of DTAA between India and Japan and statutory recognition thereof in section 90(2), permanent establishment of a Japanese entity in India cannot be charged tax at a rate higher than comparable Indian assessees carrying on same activities

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