Delhi ITAT Special bench rules 2:1 in Nokia’s favour on PE issue

Jun 05,2018

Delhi ITAT Special bench (majority view), rules in favour of Nokia Networks OY (‘assessee’, a Finnish company), holds that assessee’s Indian subsidiary (i.e. Nokia India Pvt. Ltd.) does not constitute its Permanent Establishment (‘PE’) in India; However, ITAT Special Bench (minority view) holds existence of business connection / PE in India for Nokia Networks and rules that 3.7% of the sales in India are attributable to the PE relying on Delhi ...


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