https://www.taxtmi.com/caselaws?id=286151 The Tribunal partly allowed the application by rectifying a clerical mistake in the order but found no other mistakes warranting rectification under section 254(2) of the Act. The Tribunal upheld the existence of a Permanent Establishment (PE) in India for the applicant, rejecting the argument that it came into existence at a later date. Additionally, the Tribunal clarified that certain revenue attributions to the PE were not indicative of income earned during the relevant period. The Tribunal also affirmed that the activities of the project office were not merely preparatory or auxiliary, finding no errors in its previous findings. en-us Fri, 31 May 2013 00:00:00 +0530 Fri, 14 Feb 2020 12:19:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286151 The Tribunal partly allowed the application by rectifying a clerical mistake in the order but found no other mistakes warranting rectification under section 254(2) of the Act. The Tribunal upheld the existence of a Permanent Establishment (PE) in India for the applicant, rejecting the argument that it came into existence at a later date. Additionally, the Tribunal clarified that certain revenue attributions to the PE were not indicative of income earned during the relevant period. The Tribunal also affirmed that the activities of the project office were not merely preparatory or auxiliary, finding no errors in its previous findings. Case-Laws Income Tax Fri, 31 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286151