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2021 (9) TMI 913 - AT - Income TaxIncome taxable in India - balance receipts not attributable to PE in India - whether the balance receipts not attributable to permanent establishment of the assessee can be taxed as fees for technical services under Article-13 of the India-UK Tax Treaty - HELD THAT:- As issue raised in the present appeal is identical to the issues raised in the assessee's own case for A.Ys. 2010-11 to 2016-17 and in those years the issues has been decided against the assessee. In the absence of any distinguishing feature in the facts of the case in the year under consideration and that of the earlier years, we following the decision of the Co-ordinate Bench of Tribunal in assessee's own case for A.Y. 2010-11 [2016 (11) TMI 65 - ITAT DELHI] and for similar reasons dismiss the appeal of the assessee. Thus the appeal of the assessee is dismissed.
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