https://www.taxtmi.com/caselaws?id=442885 The Tribunal ruled in favor of the assessee, a non-resident corporate entity from Japan, determining that it did not have a Permanent Establishment (PE) in India under the Indian-Japan Double Taxation Avoidance Agreement. The Tribunal found that the alleged fixed place and supervisory PE criteria were not met, leading to the deletion of the addition made by the Assessing Officer. Additionally, the Tribunal dismissed the pre-mature ground raised by the assessee and allowed the appeal, concluding that the assessee had no PE in India. en-us Wed, 19 Apr 2023 00:00:00 +0530 Tue, 12 Sep 2023 09:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442885 The Tribunal ruled in favor of the assessee, a non-resident corporate entity from Japan, determining that it did not have a Permanent Establishment (PE) in India under the Indian-Japan Double Taxation Avoidance Agreement. The Tribunal found that the alleged fixed place and supervisory PE criteria were not met, leading to the deletion of the addition made by the Assessing Officer. Additionally, the Tribunal dismissed the pre-mature ground raised by the assessee and allowed the appeal, concluding that the assessee had no PE in India. Case-Laws Income Tax Wed, 19 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442885