https://www.taxtmi.com/caselaws?id=13406 The Tribunal's findings on the assessee's Indian operations, the existence of a permanent establishment under Article 5 of the double taxation convention, and the computation of taxable income were treated as factual determinations. It also upheld application of section 145 of the Income-tax Act, 1961, and regarded Instruction No. 1767 only as a guideline for working out profits. The High Court found no legal infirmity, inconsistency, or substantial question of law warranting appellate interference, and the Tribunal's order was upheld. en-us Thu, 30 Mar 2006 00:00:00 +0530 Thu, 28 May 2009 17:11:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13406 The Tribunal's findings on the assessee's Indian operations, the existence of a permanent establishment under Article 5 of the double taxation convention, and the computation of taxable income were treated as factual determinations. It also upheld application of section 145 of the Income-tax Act, 1961, and regarded Instruction No. 1767 only as a guideline for working out profits. The High Court found no legal infirmity, inconsistency, or substantial question of law warranting appellate interference, and the Tribunal's order was upheld. Case-Laws Income Tax Thu, 30 Mar 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13406