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    <title>2024 (9) TMI 1515 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the foreign assessee did not have a permanent establishment in India, following earlier co-ordinate bench decisions in the assessee&#039;s own case on an identical factual matrix. Because the permanent establishment issue was ative, the related attribution and profit estimation grounds were treated as academic and were not separately adjudicated. The primary ground was therefore decided in favour of the assessee.</description>
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      <description>The Tribunal held that the foreign assessee did not have a permanent establishment in India, following earlier co-ordinate bench decisions in the assessee&#039;s own case on an identical factual matrix. Because the permanent establishment issue was ative, the related attribution and profit estimation grounds were treated as academic and were not separately adjudicated. The primary ground was therefore decided in favour of the assessee.</description>
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