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TMI Blog2016 (8) TMI 1200X X X X Extracts X X X X X X X X Extracts X X X X ..... . P. Rastogi, Advocates. For the Respondent : Anil Kumar Sharma, Senior DR. ORDER G. D. Agrawal (Vice President) This appeal by the assessee for the assessment year 2006-07 is directed against the order of learned CIT(A)-XI, New Delhi dated 6th January, 2011. 2. The assessee has raised the following grounds of appeal :- "1. That the ld.CIT(Appeals) has failed to provide a reasonable opportu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot making even a part of this profit %. How can a branch who is simply doing a small portion of the job such as drafting and engineering can be deemed as making so high % of profit, when the most of the crucial job of the project lies with the HO, including the liabilities of the design if the building fails at any given time. 4. That in the absence of any income embedded in the amount reimburse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to uphold the addition made by the AO. (ii) That in the absence of any comparables brought on record either by the AO or by CIT(Appeals) the addition of Rs. 17,98,320 as sustained by CIT(Appeals) is arbitrary, without any basis and bad in law. (iii) That the AO and CIT(Appeals) have not given any valid reason in adopting the markup rate @ 10% instead of the global rate @5.33% as per US tax re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1598/Del/2009. He stated that the ITAT has not accepted the assessee's contention that there is no PE in India. The ITAT has given the direction how the profit is to be attributed to the PE in India. He, therefore, submitted that for the year under consideration also, the income may be computed as per the direction of the ITAT in earlier years. 4. Learned DR has no objection to the above submiss ..... X X X X Extracts X X X X X X X X Extracts X X X X
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