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2018 (1) TMI 1705 - ITAT MUMBAIIncome chargeable to tax in India - Income attributable on account of PE - Transaction between the assessee and its AE found at arms length price on the issue of agent for space selling - HELD THAT:- Once no income chargeable to tax in India is attributable to the assessee for the reason that the transaction between the assessee and its AE has been found at arms length price, no further income chargeable to tax in India can be said to be attributable on account of PE. Accordingly, this issue is squarely covered in favour of assessee by the decision of Hon’ble Supreme Court in the case of E-Funds IT Solution Inc. [ [2017 (10) TMI 1011 - SUPREME COURT] and alsocase of Taj TV Ltd. [2016 (12) TMI 1291 - ITAT MUMBAI] and ZEE TV USA INC[2017 (11) TMI 1642 - ITAT MUMBAI]. Respectfully following the same, we allow the cross objections of the assessee.
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