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Appellant, a UK company, had a business connection and PE in India u/s 9(1). 15% of booking fees were attributable to the PE in India, following earlier decisions for AY 2018-19 and 2019-20. Observations regarding appellant's status as a conduit entity were unnecessary and irrelevant. ITAT allowed appellant's appeal.
Appellant, a UK company, had a business connection and PE in India u/s 9(1). 15% of booking fees were attributable to the PE in India, following earlier decisions for AY 2018-19 and 2019-20. Observations regarding appellant's status as a conduit entity were unnecessary and irrelevant. ITAT allowed appellant's appeal.
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