https://www.taxtmi.com/caselaws?id=437933 The Tribunal ruled in favor of the assessee, a non-resident corporate entity from Hong Kong, in a tax dispute with the Revenue. It was held that the assessee did not have a Permanent Establishment (PE) in India, and thus, section 44DA was deemed inapplicable. The income treated as Fee for Technical Services (FTS) under section 115A was accepted, leading to the deletion of the addition made by the Assessing Officer under section 44DA. The appeal was partly allowed in favor of the assessee. en-us Tue, 16 May 2023 00:00:00 +0530 Thu, 18 May 2023 08:38:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437933 The Tribunal ruled in favor of the assessee, a non-resident corporate entity from Hong Kong, in a tax dispute with the Revenue. It was held that the assessee did not have a Permanent Establishment (PE) in India, and thus, section 44DA was deemed inapplicable. The income treated as Fee for Technical Services (FTS) under section 115A was accepted, leading to the deletion of the addition made by the Assessing Officer under section 44DA. The appeal was partly allowed in favor of the assessee. Case-Laws Income Tax Tue, 16 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437933