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2012 (10) TMI 245 - AT - Income TaxIndia Japan DTAA/treaty - Existence of PE - Assessee's contention is that Indian company acted as a communication channel between the prospective customers and assessee - Indian company facilitated the flow of information and documents like enquiries, proposals, quotations, purchase orders, invoice etc. between the assessee and the customers - AO has not accepted assessee's explanation as required documentary evidences were not furnished – Held that:- As concluding from the facts of the case there are conflicting claim by the Revenue and the assessee. Before the AO assessee had pleaded that the person who was in charge of the requisite details had fallen ill. It has also been a claim of the assessee that its submission had not been appreciated properly. Issues are remitted to the file of the AO for de novo consideration. Appeal remand back to AO
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