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2020 (9) TMI 922 - AT - Income TaxDependent Agency Permanent Establishment of the assessee company in India - Income accrued in India - HELD THAT:- We find the issue stands squarely covered in favour of the assessee by the decision of the Tribunal in assessee’s own case for asstt. Year 2005-06 wherein it was held that MIPL is not a Dependent Agency PE of the assessee. Attribution of profits to DAPE - HELD THAT:- Respectfully following the consistent decisions of the Tribunal in assessee’s own case for the preceding assessment years [2020 (2) TMI 1053 - ITAT DELHI] and in absence of any contrary material brought to our notice we hold that no further profit could be attributed since assessee is not a Dependent Agency Permanent Establishment.
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