9911796707
TMI Blog2023 (1) TMI 1244X X X X Extracts X X X X X X X X Extracts X X X X ..... Jain with Mr. Nischay Kantoor, Advocates. ORDER [Physical Hearing/Hybrid Hearing (as per request)] 1. This appeal concerns Assessment Year (AY) 2009-2010, and is directed against the order dated 04.01.2022 passed by the Income Tax Appellate Tribunal [in short "Tribunal"]. 2. The appellant/revenue has proposed the following questions of law. "A. Whether on the facts and circumstance of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n law, the Ld. ITAT has erred in holding that no income is liable to be attributed in India as Mitsui India Pvt. Ltd. (MIPL), the liaison office of the assessee, do not constitute a Dependent Agency Permanent Establishment (DAPE) of the assessee in India? E. Whether on the facts and circumstance of the case and in law, the Ld. ITAT erred in holding that the assessee's income from Teesta and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed questions, shown as A and E in the instant appeal. 6. Insofar as the remaining questions are concerned i.e., those shown as B, C and D, they are covered, even according to Mr. Sanjay Kumar, by the judgment of the coordinate bench dated 09.11.2022 passed in ITA 321/2018 titled The Commissioner of Income Tax-International Tax v. Mitsui & Company Ltd. 7. Accordingly, this appeal is closed, as no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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