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2021 (9) TMI 1285 - HC - Income TaxIncome accrued in India - PE in India - Whether assessee has a business connection in India under Section 9(1)(i) of the Income Tax Act, 1961 and has a PE, in the form of M/s L.G. Electronics India Ltd. under Article 5(1) & 5(2) of DTAA between India and Korea? - HELD THAT:- As LG Electronics India Limited [2020 (11) TMI 209 - ITAT DELHI] covers the case of the present Respondent-assessees for the assessment years under consideration wherein the CIT(A) in the 201 proceedings held that none of the AEs, apart from LG Korea, had PE in India.
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