A non-resident entity or the foreign company having an IT-enabled BPO in India, would be liable to tax in India only if:
A. The BPO unit constitutes it is permanent establishment
B. The BPO unit is not covered by the Safe-harbour rules
C. The foreign company is located in Non-Jurisdictional Area
D. There is no DTAA between India and the country to which the foreign company belongs
Answer: Option A
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