https://www.taxtmi.com/caselaws?id=199306 A dispute on permanent establishment under Article 5 of the Double Taxation Avoidance Agreement and the applicability of section 44B turned on case-specific facts about an Indian agent and the absence of material showing non-arm's-length dealings. The analysis noted that the Tribunal confined itself to the relevant assessment year and proceeded on the basis that Article 5(5) read with Article 5(6) was examined. Because no broader legal issue was decided and the factual foundation for the Revenue's challenge was missing, no substantial question of law arose. The Revenue's challenge therefore failed, and the assessee succeeded. en-us Sat, 15 Nov 2014 00:00:00 +0530 Sun, 25 Feb 2018 21:52:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=199306 A dispute on permanent establishment under Article 5 of the Double Taxation Avoidance Agreement and the applicability of section 44B turned on case-specific facts about an Indian agent and the absence of material showing non-arm's-length dealings. The analysis noted that the Tribunal confined itself to the relevant assessment year and proceeded on the basis that Article 5(5) read with Article 5(6) was examined. Because no broader legal issue was decided and the factual foundation for the Revenue's challenge was missing, no substantial question of law arose. The Revenue's challenge therefore failed, and the assessee succeeded. Case-Laws Income Tax Sat, 15 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=199306