2022 (12) TMI 1387 - AT - Income Tax

Fixed place PE/dependent agent PE - Existence or otherwise of a Permanent Establishment (PE) in India - attribution of profit to the PE - assessee is a non-resident corporate entity incorporated in Singapore - HELD THAT:- As decided in own case [2022 (5) TMI 674 - ITAT DELHI] issues arising for consideration are squarely covered by the decision of the Tribunal in assessee’s own case in assessment year 2017-18, respectfully following the same, we hold that the assessee had no PE in India. Decided in favour of assessee.