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2018 (8) TMI 1135 - AT - Income Tax
Existence of permanent establishment in India (PE) - DRP observed that in the absence of a permanent establishment the action of the AO proposing to attribute 32% of total receipts from supply of software as taxable business profits is not correct. - Held that:- the issue is covered in favour of the assessee as decided by the Tribunal in [2013 (9) TMI 374 - ITAT MUMBAI] - Decided in favor of assessee.