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2021 (9) TMI 1129 - AT - Income TaxDependent Agent Permanent Establishment (DAPE) - income attributable for the PE of the assessee - HELD THAT:- It is not disputed that the AE has not been remunerated at ALP, no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. Since, without prejudice to the ground is adjudicated in favour of the assessee, we are not adjudicating other grounds in this regard. Treatment of royalty - HELD THAT:- We note that the issue is now covered in favour of the assessee ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED VERSUS THE COMMISSIONER OF INCOME TAX & ANR. [2021 (3) TMI 138 - SUPREME COURT] - Decided in favour of the assessee.
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