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2022 (9) TMI 1313 - AT - Income TaxIncome deemed to accrue or arise in India - PE in India - profit attributable to the PE in India - company registered and incorporated under the laws of Sweden as contemplated under Article 4 of the India- Sweden Double Taxation Avoidance Agreement - HELD THAT:- As we find that the same issue has been decided by the ITAT [2022 (2) TMI 1287 - ITAT DELHI] consistently in assessee’s favour. The DRP order of AY 2011-12 [2020 (10) TMI 1205 - ITAT DELHI] which has been preferred and referred by AO as well as by CIT (A) has not been upheld by the ITAT and the ITAT has reversed the decision and decided the issue in favour of the assessee. Since no distinguishing features on the facts of this year and earlier years were brought to our notice, nor it is the case that any of the orders have been reversed by Hon’ble jurisdictional High Court, we follow the order of the coordinate Benches of the ITAT and set aside the orders of the Revenue authorities.
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