https://www.taxtmi.com/caselaws?id=301843 Permanent establishment under Article 5 of the India-UAE DTAA was treated as absent where the same contractual framework and business activities had already been examined in earlier years and the jurisdictional High Court had reached that finding. The prior determination was regarded as binding because the facts remained unchanged, preventing the permanent establishment question from being reopened. Consequently, offshore supply and onshore service receipts were not taxable in India on the basis of a permanent establishment, and the deletion of related additions was sustained. en-us Mon, 18 Nov 2019 00:00:00 +0530 Fri, 22 Apr 2022 21:50:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301843 Permanent establishment under Article 5 of the India-UAE DTAA was treated as absent where the same contractual framework and business activities had already been examined in earlier years and the jurisdictional High Court had reached that finding. The prior determination was regarded as binding because the facts remained unchanged, preventing the permanent establishment question from being reopened. Consequently, offshore supply and onshore service receipts were not taxable in India on the basis of a permanent establishment, and the deletion of related additions was sustained. Case-Laws Income Tax Mon, 18 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301843