https://www.taxtmi.com/caselaws?id=420254 The Court directed that if the petitioners file an application for FY 2022-2023 under Section 197, the Assessing Officer (AO) must address the contentions raised, particularly regarding profit attribution to the Permanent Establishment (PE), in accordance with the law. The Court emphasized that its observations would not influence the AO's decision on the fresh application. The writ petitions were disposed of under these terms, and any pending applications were closed. en-us Fri, 25 Mar 2022 00:00:00 +0530 Wed, 30 Mar 2022 08:34:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420254 The Court directed that if the petitioners file an application for FY 2022-2023 under Section 197, the Assessing Officer (AO) must address the contentions raised, particularly regarding profit attribution to the Permanent Establishment (PE), in accordance with the law. The Court emphasized that its observations would not influence the AO's decision on the fresh application. The writ petitions were disposed of under these terms, and any pending applications were closed. Case-Laws Income Tax Fri, 25 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420254