Tax Dispute Resolved: Permanent Establishment Income Taxation Overturned Based on Consistent Precedent and Procedural Interpretation

ITAT adjudicated a tax dispute regarding permanent establishment (PE) income taxation. The tribunal referenced its previous ruling in the assessee's own case, finding consistent factual circumstances. Given no material changes from the prior year, the tribunal followed its precedent and ruled in favor of the assessee. The Assessing Officer's addition of business income related to fixed place PE, subject to 40% surcharge and taxes, was deemed unsustainable and consequently deleted. The tribunal allowed the assessee's grounds, effectively reversing the original tax assessment and providing tax relief based on procedural consistency and prior judicial interpretation. .....

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