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International TaxArticle·28 September 2026

ITAT says Supervisory PE Requires More Than Employee Presence

By J the App

Executive Summary

Toyota Tsusho's employees were present in India across several customer locations, and the AO aggregated their days to establish a Supervisory PE. ITAT held that the treaty conditions are cumulative, the duration test must be applied project-wise, and no qualifying installation or assembly project was established even for Toyota Lakozy.

Domain | International Tax | DT

The Position

Article 5(4) of the I...

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