https://www.taxtmi.com/highlights?id=65853 TDS u/s 195 - profit attributable to the PE in India - the privity of contract is between the assessee and Indian customers, wherein, CCPL has no role to play. The aforesaid factual position emerging on record could not be effectively controverted by the Revenue through proper evidence. - the assessee cannot be construed as a dependent agent PE of CCPL - CIT(A) rightly deleted the additions - AT en-us Wed, 28 Sep 2022 16:33:59 +0530 Wed, 28 Sep 2022 16:33:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=65853 TDS u/s 195 - profit attributable to the PE in India - the privity of contract is between the assessee and Indian customers, wherein, CCPL has no role to play. The aforesaid factual position emerging on record could not be effectively controverted by the Revenue through proper evidence. - the assessee cannot be construed as a dependent agent PE of CCPL - CIT(A) rightly deleted the additions - AT Highlights Income Tax Wed, 28 Sep 2022 16:33:59 +0530 https://www.taxtmi.com/highlights?id=65853