https://www.taxtmi.com/caselaws?id=438155 The Tribunal held that the non-resident corporate entity from Malaysia did not have a fixed place Permanent Establishment (PE) in India under the India-Malaysia Double Taxation Avoidance Agreement. The Revenue's attribution of revenue to the PE was also rejected due to insufficient evidence of the PE's existence. The Tribunal remanded the issues of revenue attribution and taxability of offshore supplies back to the Assessing Officer for further verification. All consequential matters were also referred back to the AO for fresh determination, allowing the assessee a fair chance to present its case. Appeals were allowed for statistical purposes. en-us Mon, 22 May 2023 00:00:00 +0530 Tue, 23 May 2023 12:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438155 The Tribunal held that the non-resident corporate entity from Malaysia did not have a fixed place Permanent Establishment (PE) in India under the India-Malaysia Double Taxation Avoidance Agreement. The Revenue's attribution of revenue to the PE was also rejected due to insufficient evidence of the PE's existence. The Tribunal remanded the issues of revenue attribution and taxability of offshore supplies back to the Assessing Officer for further verification. All consequential matters were also referred back to the AO for fresh determination, allowing the assessee a fair chance to present its case. Appeals were allowed for statistical purposes. Case-Laws Income Tax Mon, 22 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438155