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of <h1>Appeals Allowed: No Permanent Establishment Found in India</h1> The SC allowed the appeals, overturning the HC judgment, as no permanent establishment in India was found by the Dispute Resolution Panel. - TMI Reopening of assessment - reasons to believe - Income accrued in India - Permanent establishment - attribution of profits - HELD THAT:- In view of the fact that the Dispute Resolution Panel has found that there is no permanent establishment in India, the judgment of the High Court is set-aside and the appeals are allowed accordingly The Supreme Court of India allowed the appeals as the Dispute Resolution Panel found no permanent establishment in India, setting aside the High Court judgment. (Citation: 2017 (11) TMI 1922 - SC Order)
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