The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 5 June 2013 in the case of Germanischer Lloyd AG v. DDIT (2013)35 taxmann.com 347 (Mumbai-Trib) on the issue of profit split between a head office (HQ) in Germany and its permanent establishment in India.
(a) Facts. The Taxpayer (i.e. Germanischer Lloyd AG) is a classification society established in Germany and is engaged in providing inspection and certification services to the maritime industry. All sea faring/voya…