https://www.taxtmi.com/caselaws?id=173602 The dispute concerned whether the respondent constituted a Permanent Establishment under the applicable Double Taxation Avoidance Agreement. The Court treated the matter as one turning on the factual finding that no Permanent Establishment existed for the relevant assessment year, and noted that an assessment year is a unit by itself. Finding no sufficient basis to interfere with the concurrent finding below, the Court left the determination undisturbed and the issue was answered in favour of the assessee and against the Revenue. en-us Tue, 26 Aug 2008 00:00:00 +0530 Fri, 18 Sep 2015 12:38:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173602 The dispute concerned whether the respondent constituted a Permanent Establishment under the applicable Double Taxation Avoidance Agreement. The Court treated the matter as one turning on the factual finding that no Permanent Establishment existed for the relevant assessment year, and noted that an assessment year is a unit by itself. Finding no sufficient basis to interfere with the concurrent finding below, the Court left the determination undisturbed and the issue was answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Tue, 26 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173602