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2023 (8) TMI 165 - SCH - Income TaxIncome taxable in India - Income attributable to the operations carried out in India - attribution of only 15% of the revenue as income accruing /arising in India - Permanent establishment in India - HELD THAT:- As in view of case Director of Income Tax, New Delhi vs. Travelport Inc.[2023 (5) TMI 227 - SUPREME COURT] and having regard to the fact that the Coordinate Bench observed that since the first issue was held against the department, it was not necessary to go into the second issue, namely, the question regarding permanent establishment. Therefore, appropriate orders may be made in these cases filed by the assessee(s). We find that though the High Court has stated that there was no substantial question of law in the appeals filed by the assessee(s) before the High Court, the fact remains that at this stage going into the question as to whether there was a permanent establishment of the assessee(s) in India is now wholly academic and therefore would not require consideration and answer in these appeals.
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