Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2018 (1) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (1) TMI 1470 - DELHI HIGH COURTThe following questions of law arise:- (1) Did ITAT fell into error in its findings with respect to existence of a fixed place Permanent Establishment (PE) of the assessee in India? (2) Did ITAT fell into error in concluding that assessee/appellant’s separately independent agent PE, was located in India? (3) Whether on the facts and the circumstances of the case and the law, the ITAT was justified in attributing as high as 35% of the profits to the alleged marketing activities and thereafter, attributing 75% of such 35% profits to the alleged PE of the Appellant in India?
|