Burden of proving Foreign Assessee has a PE in India to levy Income Tax is on the Dept: ITAT grants relief to KFC Franchise [Read Order]

The Income Tax Appellate Tribunal (ITAT), while dismissing the appeal by the revenue held that Burden of proving foreign assessee has a Permanent Establishment (PE) in India, so to be taxed on the business generated by such PE is on the Revenue Department. The assessee, M/s. Yum! Restaurants (Asia) Pte. Ltd. is a company incorporated […]

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