OrbitaxIndian Supreme Court decision on whether captive BPO activities give rise to PE and income attributable to PE on such activities
|Treaty Development|India-United States
The Supreme Court of India delivered a ruling dated 9 June 2007 in the case of Morgan Stanley & Co., United States (the Applicant) on whether the captive business process outsourcing (BPO) activities of the company gave rise to a permanent establishment (PE) in India and the amount of income attributable to the PE.
(a) Facts. For the facts (including abbreviat…
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