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TMI Blog2018 (3) TMI 477X X X X Extracts X X X X X X X X Extracts X X X X ..... ates. ORDER Admit. The question urged in this appeal for consideration is:- "(1) Whether the assessee has constituted the permanent establishment (PE) so as to attract the provisions of Section 9 of the Income Tax Act, 1961?" The impugned order itself discloses that the Income Tax Appellate Tribunal (ITAT) has followed its previous decisions of other years. One of those decisions was carried ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n by him to specific queries. The Court is unable to be persuaded that the ITAT erred in its conclusion that the evidence produced by the AO does not show that the LOs of the Assessee carried on any activity which was not incidental and auxiliary in nature. 19. It is urged by Mr. Jain that the ITAT had merely gone by the fact that the Reserve Bank of India ("RBI") had not found the Assessee to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the consistent position in this regard continuing since 1977- 78, in the absence of any evidence to suggest a change in the circumstances, there was no warrant for the AO and the CIT (A) to take a different view of the matter." Following the above decision, this Court is of the opinion that no question of law arises as the ITAT merely followed the decisions of the previous years, which have b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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