https://www.taxtmi.com/caselaws?id=217296 The Tribunal found that the factual controversy over whether the Indian entity merely facilitated communication or instead negotiated prices and secured orders had not been properly resolved. As the lower authorities relied mainly on the absence of supporting material, while the assessee said relevant documents had been furnished to the extent available and some records were not traceable, the matter required a fresh factual examination. The Tribunal therefore remitted the issues of permanent establishment, attribution of profits, and levy of interest to the Assessing Officer for de novo consideration after giving the assessee a proper opportunity of being heard. en-us Fri, 13 Jul 2012 00:00:00 +0530 Fri, 09 Sep 2016 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217296 The Tribunal found that the factual controversy over whether the Indian entity merely facilitated communication or instead negotiated prices and secured orders had not been properly resolved. As the lower authorities relied mainly on the absence of supporting material, while the assessee said relevant documents had been furnished to the extent available and some records were not traceable, the matter required a fresh factual examination. The Tribunal therefore remitted the issues of permanent establishment, attribution of profits, and levy of interest to the Assessing Officer for de novo consideration after giving the assessee a proper opportunity of being heard. Case-Laws Income Tax Fri, 13 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217296