https://www.taxtmi.com/caselaws?id=329019 The Tribunal concluded that the appeal filed by Abu Dhabi Ship Building PJSC was not maintainable under section 246A as the order under section 195(2) was not appealable under that section. The Tribunal emphasized that the appeal should have been filed by ONGC under section 248. The Tribunal upheld the Assessing Officer's determination of tax liability under section 195(2) on payments made by ONGC to Abu Dhabi Ship Building PJSC, considering the business connection in India. The Tribunal did not address the issues of Permanent Establishment, DTAA applicability, or income attribution due to the decision on the maintainability of the appeal. The Tribunal set aside the Commissioner (Appeals) order and restored the Assessing Officer's order under section 195(2). en-us Wed, 08 Jun 2016 00:00:00 +0530 Mon, 08 Aug 2022 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329019 The Tribunal concluded that the appeal filed by Abu Dhabi Ship Building PJSC was not maintainable under section 246A as the order under section 195(2) was not appealable under that section. The Tribunal emphasized that the appeal should have been filed by ONGC under section 248. The Tribunal upheld the Assessing Officer's determination of tax liability under section 195(2) on payments made by ONGC to Abu Dhabi Ship Building PJSC, considering the business connection in India. The Tribunal did not address the issues of Permanent Establishment, DTAA applicability, or income attribution due to the decision on the maintainability of the appeal. The Tribunal set aside the Commissioner (Appeals) order and restored the Assessing Officer's order under section 195(2). Case-Laws Income Tax Wed, 08 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329019