TMI Blog2024 (1) TMI 363X X X X Extracts X X X X X X X X Extracts X X X X ..... nt Establishment - 75 percent of the gross profits earned from Indian operations, attributed to the respondent/assessee sustained by DRP - HELD THAT:- Tribunal partly allowed the appeal of the respondent/assessee by following its own decision for AYs 2007-08 to 2014-15, thereby directing the Assessing Officer to adopt the attribution rate of revenue for the Indian operations of the Permanent Esta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AL): CM APPL. 64099/2023 in ITA 748/2023 [Application filed on behalf of the appellant seeking condonation of delay of 220 days in re-filing the appeal] 1. This is an application filed by the appellant/revenue, seeking condonation of delay in re-filing the appeal. 2. According to the appellant/revenue, there is a delay of 220 days in refiling the appeal. 3. Since we intend to d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he case of Commissioner of Incometax (International Taxation) v. Travelport L.P. USA, [2023] 153 taxmann.com 176 (SC). Since the order of the Supreme Court refers to a judgment of this court, the order is extracted hereafter: 1. Delay of 146 days is condoned. 2. Learned Additional Solicitor General appearing for the petitioner has submitted that the issues which arise in this petiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to 2014-15, thereby directing the Assessing Officer to adopt the attribution rate of revenue for the Indian operations of the Permanent Establishment at 15 percent of gross booking fees for the AY in issue, i.e., AY 2015-16. 8.1 The coordinate bench in AY 2006-07, while dealing with ITA 301/2022, has sustained the said conclusion and gone on to hold that no substantial question of law arose for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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