https://www.taxtmi.com/caselaws?id=310368 The ITAT ruled in favor of the non-resident corporate entity, determining that no Permanent Establishment (PE) existed in India for the assessment year 2018-19. Consequently, the Tribunal held that neither offshore supplies nor onshore services were taxable in India under section 44DA, as the Revenue failed to independently verify the facts and relied on past assessments. The decision underscored the necessity for annual verification of PE existence, leading to the dismissal of the Assessing Officer's attribution of income to a non-existent PE. en-us Tue, 13 Jun 2023 00:00:00 +0530 Wed, 06 Mar 2024 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310368 The ITAT ruled in favor of the non-resident corporate entity, determining that no Permanent Establishment (PE) existed in India for the assessment year 2018-19. Consequently, the Tribunal held that neither offshore supplies nor onshore services were taxable in India under section 44DA, as the Revenue failed to independently verify the facts and relied on past assessments. The decision underscored the necessity for annual verification of PE existence, leading to the dismissal of the Assessing Officer's attribution of income to a non-existent PE. Case-Laws Income Tax Tue, 13 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310368