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of Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer attributed 25% of the profit to the PE in India, only one contract was thoroughly examined, neglecting others. The Tribunal found this attribution to be arbitrary and lacking proper analysis. The estimation of profit rate at 10% was deemed unjustified, especially considering the Assessee's evidence of a lower global profit rate. The Tribunal, therefore, directed a de novo adjudication by the Assessing Officer after considering all relevant factors and providing a reasonable opportunity to the Assessee.
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