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2015 (2) TMI 1353 - AT - Income TaxBusiness connection in India u/s 9(1)(i) - profits attributable to India - attribution of taxable income to the so called ‘business connection’ in India - HELD THAT:- This decision has been reiterated by the Tribunal in A.Y. 2008-09 vide order dated 21.05.2014 [2014 (5) TMI 1209 - ITAT MUMBAI] Thus, without going into other decision of the Tribunal as cited by Ld. DR, we respectfully following the judicial precedence of the earlier years, decide this issue in favour of the assessee by holding that the assessee’s income from transportation agreement cannot be taxed in India under the deeming provision of section 9(1)(i) as USIPL cannot be said to constitute business connection in India. Accordingly, Ground No. 1 as raised by the assessee stands allowed.
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