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HomeDirect TaxNo PE for Oracle Systems in India: ITAT Deletes Notional Royalty Additions 

No PE for Oracle Systems in India: ITAT Deletes Notional Royalty Additions 

Direct Tax

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By Mariya Paliwala
No PE for Oracle Systems in India: ITAT Deletes Notional Royalty Additions

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The Income Tax Appellate Tribunal (ITAT), Delhi Bench, has ruled in favour of Oracle Systems Corporation, deleting major additions made on account of alleged notional royalty and setting aside findings that its Indian subsidiary constituted a Permanent Establishment (PE) in India for Assessment Years 2006-07 to 2012-13. The bench of Raj Kumar Chauhan (Judicial Member)…

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Mariya Paliwala
Mariya Paliwalahttps://www.jurishour.in/
Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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