TMI Blog2022 (11) TMI 1346X X X X Extracts X X X X X X X X Extracts X X X X ..... urt in the case of the respondent-assessee itself [ 2018 (3) TMI 434 - DELHI HIGH COURT] after considering the survey report held that the Liaison office of the assessee did not constitute a Permanent Establishment (for short PE ). Consequently, the first two substantial questions of law do not arise for consideration in the present appeal. Dependent agency PE to the assessee liable to tax i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... circumstances of the case and in law, whether the ITAT erred in holding that Liaison Office of the assessee did not constitute a permanent Establishment, liable to tax in India when the said office was clearly a fixed place and the activities carried out, could not be said to be preparatory or auxiliary in nature? 2. Whether ITAT/CIT(A) erred in holding that the Liaison office does not const ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of material, it cannot be taken as dependent agency PE to the assessee liable to tax in India. Since the said finding has not been challenged on the ground of perversity, even the third substantial question of law does not arise for consideration. Accordingly, no substantial question of law arises for consideration in the present appeal and the same is dismissed. - - TaxTMI - TMITax - Inc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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