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2022 (3) TMI 1292 - HC - Income TaxApplication u/s 197 - profits to the Permanent Establishment (PE) of the petitioner therein in India, at the rate of 26% - HELD THAT:- In case the petitioners were to move an application u/s 197 of the Act for FY 2022-2023, and if the contentions raised in the writ petitions form part of the said application, including what is noted hereinabove by us with regard to the attribution of profits to the PE, the same will be dealt with by the AO, as per law. At this stage, Mr Jolly says that the petitioners will move an application for the F.Y.2022-2023, within four weeks of receipt of a copy of this order. In case, such an application is moved, the AO will dispose of the same within four weeks of the receipt of the application.
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