TMI Blog2019 (2) TMI 1963X X X X Extracts X X X X X X X X Extracts X X X X ..... ian Premier league in September 2007. The assessee entered into an initial contract and subsequent separate service agreement for the services to be provided to the board of control for Cricket in India in relation to IPL. For the purpose of provision of the services it deputed some of its employees for undertaking the on ground implementation and elated supervision activities in India. The stay of these employees has exceeded the threshold limit of 90 days in India and hence the assessee was having a permanent establishment under article 5 of the DTAA. The assessee attributed 63% of the total receipts from the board of control for Cricket in India as attributable to such PE and balance receipt of 37% was held to be not taxable in India. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The learned departmental representative also did not express any concern about granting early hearing to the assessee in the impugned appeal. 3. On careful consideration of the application of the assessee it is apparent that the assessee wants that as the issue involved in this appeal is squarely covered, so, it may be decided on the basis of the order of the coordinate bench in assessee‟s own case for the earlier year. In view of this we grant early hearing of the impugned appeal. Accordingly the application of the assessee is allowed. 4. Further both the parties submitted that the issue is squarely covered against the assessee in assessee‟s own case by the decision of the coordinate bench for earlier years and therefore ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the board of control for Cricket in India as attributable to such PE and balance receipt of 37% was held to be not taxable in India. This was the stand taken by the assessee. According to that the receipt of ₹ 99912355/ were not taxable in India. Learned assessing officer held that the above sum is taxable as fees for technical services. Accordingly the assessment order u/s 143 (3) read with section 144C (13) was passed on 13/2/2018. Against this order the assessee is in appeal before us. 6. Both the parties submitted before us that the above issue is squarely covered against the assessee by the decision of the coordinate bench in assessee‟s own case for assessment year 2010 11 dated 4/10/2016 as well as for assessmen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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