https://www.taxtmi.com/caselaws?id=456413 The dispute was confined to quantification of profit attributable to the alleged Indian permanent establishment and the claimed duplication of supervisory service revenue. The merits of the permanent establishment issue and the composite contract issue were not pursued. As the assessee could not furnish a complete reconciliation of invoices, receipts, and income already offered to tax, the computation required further verification. The ITAT therefore remitted the matter to the Assessing Officer and Transfer Pricing Officer for fresh examination and limited re-determination of the taxable profit attributable to Indian operations. en-us Wed, 18 Oct 2023 00:00:00 +0530 Tue, 23 Jul 2024 20:12:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456413 The dispute was confined to quantification of profit attributable to the alleged Indian permanent establishment and the claimed duplication of supervisory service revenue. The merits of the permanent establishment issue and the composite contract issue were not pursued. As the assessee could not furnish a complete reconciliation of invoices, receipts, and income already offered to tax, the computation required further verification. The ITAT therefore remitted the matter to the Assessing Officer and Transfer Pricing Officer for fresh examination and limited re-determination of the taxable profit attributable to Indian operations. Case-Laws Income Tax Wed, 18 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456413