2024 (4) TMI 205

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..... ncome is liable to attributable in India even MIPL is taken as Dependent Agency PE to the assessee in India? - As decided by HC [ 2022 (11) TMI 1346 - DELHI HIGH COURT] Liaison office of the assessee did not constitute a Permanent Establishment AND MIPL is not performing additional function and in absence of material, it cannot be taken as dependent agency PE to the assessee liable to tax in India .....

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..... GARATHNA And HON'BLE MR. JUSTICE AUGUSTINE GEORGE MASIH For the Petitioner : Mr. N Venkatraman, A.S.G. Ms. Nisha Bagchi, Sr. Adv. Mr. Raj Bahadur Yadav, AOR Mr. Prasenjeet Mohapatra, Adv. Mr. Shashank Bajpai, Adv. Mr. Navanjay Mahapatra, Adv. Mr. Raghav Sharma, Adv ORDER UPON hearing the counsel the Court made the following. There is gross delay of 395 days in filing this special leave petitio .....

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