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2022 (11) TMI 1346 - DELHI HIGH COURTIncome taxable in India - PE in India - Liaison Office in India - whether no income is liable to attributable in India even MIPL is taken as Dependent Agency PE to the assessee in India? - HELD THAT:- Admittedly, the learned predecessor Division Bench of this Court in the case of the respondent-assessee itself [2018 (3) TMI 434 - DELHI HIGH COURT] after considering the survey report held that the Liaison office of the assessee did not constitute a Permanent Establishment (for short ‘PE’). Consequently, the first two substantial questions of law do not arise for consideration in the present appeal. Dependent agency PE to the assessee liable to tax in India - As this Court finds that both CIT(A) and ITAT have given concurrent findings of fact that MIPL is not performing additional function and in absence of material, it cannot be taken as dependent agency PE to the assessee liable to tax in India. Since the said finding has not been challenged on the ground of perversity, even the third substantial question of law does not arise for consideration.
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