https://www.taxtmi.com/caselaws?id=301812 Under Article 5 of the India-UAE DTAA, the Tribunal reiterated that no permanent establishment existed in India on identical facts already decided in the assessee's favour for earlier years, with that view affirmed by the High Court. On that basis, attribution of profits to the alleged permanent establishment, including from offshore supply and onshore service segments, could not be sustained. The appellate relief in favour of the assessee was therefore maintained, and the Revenue's appeal was dismissed. en-us Fri, 14 Jun 2019 00:00:00 +0530 Thu, 21 Apr 2022 20:56:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301812 Under Article 5 of the India-UAE DTAA, the Tribunal reiterated that no permanent establishment existed in India on identical facts already decided in the assessee's favour for earlier years, with that view affirmed by the High Court. On that basis, attribution of profits to the alleged permanent establishment, including from offshore supply and onshore service segments, could not be sustained. The appellate relief in favour of the assessee was therefore maintained, and the Revenue's appeal was dismissed. Case-Laws Income Tax Fri, 14 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301812