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Whether E-Funds India is a fixed place permanent establishment ('Fixed PE') of E-Funds Corporation?

Whether any profits should be attributed to the Permanent Establishment, if it exists at all, when the transactions were entered on arm's length price?


In order to constitute Fixed PE, the assessee must, first, have a fixed place of business and, second the assessee should exercise sufficient control over the said place.

Provision of support services by an entity in India would not make the entity a Permanent Establishment of a foreign entity.

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