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2021 (10) TMI 1023 - AT - Income TaxIncome accrued in India - Business Connection and Permanent Establishment - AO in conclusion held that the assessee has PE in India has a BC and PE in India - HELD THAT:- The issue of Appellant's PE/BC in India is covered against it by the above decisions of Hon'ble Delhi High Court [2014 (8) TMI 902 - DELHI HIGH COURT] and Hon'ble Delhi ITAT. [2011 (3) TMI 1819 - ITAT DELHI]in Appellant's predecessor's case. Excessive attribution to alleged PE of the Appellant in India - manner of attribution i.e. whether attribution is on sales or the net profits- HELD THAT:- PE attribution at 15% of gross revenue less the expenses (as already allowed by the Ld. AO and Ld. DRP), as per the decision of Galileo International Inc (GII) [2011 (3) TMI 1819 - ITAT DELHI] reduces the taxable income to Nil and thus, no income is taxable in India.
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