TMI Blog2023 (1) TMI 1244X X X X Extracts X X X X X X X X Extracts X X X X ..... liary in nature? - income as liable to be attributed in India - Dependent Agency Permanent Establishment (DAPE) of the assessee in India? - HELD THAT:- Questions covered, by the judgment of the coordinate bench passed in case of Mitsui Company Ltd. [ 2022 (11) TMI 1346 - DELHI HIGH COURT ] No substantial questions of law arise for consideration. - ITA 38/2023 - - - Dated:- 31-1-2023 - Hon&# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 44BBB of the Act? B. Whether on the facts and circumstance of the case and in law, the Ld. ITAT erred in holding that the 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? C. Whether on the facts a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... There is no dispute, that the only issue which arose for consideration before the Tribunal concerned the following aspect i.e., whether or not the respondent/assessee had a Dependent Agency Permanent Establishment (DAPE) in India. Therefore, the questions of law, as noticed above, have been proposed in the appeal. 4. Clearly, only questions shown as B, C and D arise for consideration in the pre ..... X X X X Extracts X X X X X X X X Extracts X X X X
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