Permanent establishment and income attribution issues raised no substantial question of law; Revenue's appeals were dismissed.

The Revenue's appeals on business connection, permanent establishment, attribution of income and reopening of assessment were found to raise no substantial question of law. The Delhi HC relied on earlier orders in connected matters and the CIT(A)'s finding that none of the assessee's associated enterprises, other than LG Korea, had a permanent establishment in India. As the same issue was already covered by prior decisions, the Court declined interference and dismissed the appeals.

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Issues: Whether the Revenue's appeals raised any substantial question of law on the issues of business connection, permanent establishment, attribution of income, and reopening of assessment.

Analysis: The appeals were considered in the context of earlier orders of the Court in connected matters and the decision of the Commissioner of Income Tax (Appeals) that none of the assessee's associated enterprises, other than LG Korea, had a permanent establishment in India. In view of the same issue arising in the present proceedings, the Court found no substantial question of law warranting interference.

Conclusion: No substantial question of law arose and the Revenue's appeals were dismissed.

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