No Penalty u/s 271(1)(c) Due to Lack of Proof of Permanent Establishment in India.

Penalty u/s 271(1)(c) - There is no conclusive proof that the assessee has PE in India. In the penalty proceedings the AO simply relied on the MAP proceedings in holding that the assessee has PE in India which in fact is not correct. - there is no concealment of income or furnishing inaccurate particulars of such income by the assessee - No penalty - AT .....

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