https://www.taxtmi.com/caselaws?id=307450 The Tribunal ruled in favor of the assessee, determining that KIPL does not constitute a Dependent Agent Permanent Establishment (DAPE) of the assessee. Consequently, the Tribunal directed the Assessing Officer (AO) to delete the impugned addition related to the attribution of profits. Offshore supplies were deemed non-taxable under the Act or DTAA. The Tribunal also dismissed the Revenue's appeal concerning the levy of interest under section 234B, citing the Supreme Court's precedent. Furthermore, the Tribunal found the CIT(A)'s direction on the Bank Guarantee computation to be without jurisdiction. en-us Fri, 30 Dec 2022 00:00:00 +0530 Wed, 27 Dec 2023 10:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307450 The Tribunal ruled in favor of the assessee, determining that KIPL does not constitute a Dependent Agent Permanent Establishment (DAPE) of the assessee. Consequently, the Tribunal directed the Assessing Officer (AO) to delete the impugned addition related to the attribution of profits. Offshore supplies were deemed non-taxable under the Act or DTAA. The Tribunal also dismissed the Revenue's appeal concerning the levy of interest under section 234B, citing the Supreme Court's precedent. Furthermore, the Tribunal found the CIT(A)'s direction on the Bank Guarantee computation to be without jurisdiction. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307450