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2015 (5) TMI 345 - AT - Income TaxEntitlement to the benefit granted under Section 9(1)(i) - procurement of goods for the purpose of exports - Assessing Officer treating the Tesco International Sourcing Limited - India Liaison Office as PE of the assessee - Held that:- Respectfully following the decisions of the Hon'ble Karnataka High Court ( 2015 (4) TMI 505 - KARNATAKA HIGH COURT) and that of the co-ordinate bench of this Tribunal in the assessee's own case for Assessment Years 2003-04 to 2007-08 [2014 (1) TMI 799 - ITAT BANGALORE] by taking into account all the aspects of the facts and circumstances of the issue as deliberated upon above and also in consonance with the judicial views (supra), we are of the view that Explanation 1(b) to s. 9(1)(i) of the Act is clearly applicable to the assessee’s case and, thus, no income was derived by the assessee in India through its operations as LO in India. - Decided in favour of assessee.
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