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2023 (5) TMI 1275 - ITAT MUMBAIIncome deemed to accrue or arise in India - PE in India - existence of a DAPE - whether Appellant has a business connection in India as per the provisions of section 9(1)(i) ? - scope of India-Ireland tax treaty - HELD THAT:- As issues raised by the assessee in the present assessment year are exactly similar to the issues decided by the Coordinate Bench in A.Y. 2015-162022 (11) TMI 31 - ITAT MUMBAI], we are inclined to follow the decision wherein as held there was no fixed place permanent establishment on the facts of this case. As regards the existence of the dependent agency permanent establishment, that aspect of the matter, is wholly tax-neutral and does not, therefore, need our adjudication. Decided in favour of assessee.
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