INTERNATIONAL TAXATION : Where assessee, permanent establishment of Japanese company, was assessed as not being a domestic company and tax rate of 65 per cent was imposed on assessee, since clause 24(2) of DTAA agreement between Indian and Japan provides that a permanent establishment of an entity of one country in other country shall not be subjected to less favourable terms than an assessee carrying on similar activities in other country,
from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000189994/hc-set-aside-itat’s-order-justifying-levy-of-65-tax-rate-on-pe-of-japanese-co-in-india.aspx
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