https://www.taxtmi.com/caselaws?id=447549 Delay in re-filing the appeals was condoned, and the unresolved transfer pricing issue was remitted for adjudication. The Tribunal had decided only the permanent establishment question, finding no fixed place or dependent agent permanent establishment in India, while treating the arm's length price and profit attribution issue as academic. Because that alternative issue remained undecided, the matter was sent back to the Tribunal for a ruling on that issue without disturbing the existing findings, with liberty to pursue a statutory appeal after remand. en-us Thu, 21 Dec 2023 00:00:00 +0530 Fri, 29 Dec 2023 07:58:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447549 Delay in re-filing the appeals was condoned, and the unresolved transfer pricing issue was remitted for adjudication. The Tribunal had decided only the permanent establishment question, finding no fixed place or dependent agent permanent establishment in India, while treating the arm's length price and profit attribution issue as academic. Because that alternative issue remained undecided, the matter was sent back to the Tribunal for a ruling on that issue without disturbing the existing findings, with liberty to pursue a statutory appeal after remand. Case-Laws Income Tax Thu, 21 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447549