https://www.taxtmi.com/caselaws?id=459523 Existence of a permanent establishment in India and attribution of income from offshore supplies must be determined from the relevant contracts and the allocation of work for the year concerned, not merely by relying on findings from earlier assessment years. Because the complete contract documents were not examined, the factual foundation for deciding PE existence and taxability was incomplete. The matter was therefore remanded for fresh adjudication after consideration of the relevant contracts and connected materials, with a reasonable opportunity of hearing to the assessee. The appeals were thus disposed of without a merits determination. en-us Fri, 11 Nov 2022 00:00:00 +0530 Tue, 17 Dec 2024 18:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459523 Existence of a permanent establishment in India and attribution of income from offshore supplies must be determined from the relevant contracts and the allocation of work for the year concerned, not merely by relying on findings from earlier assessment years. Because the complete contract documents were not examined, the factual foundation for deciding PE existence and taxability was incomplete. The matter was therefore remanded for fresh adjudication after consideration of the relevant contracts and connected materials, with a reasonable opportunity of hearing to the assessee. The appeals were thus disposed of without a merits determination. Case-Laws Income Tax Fri, 11 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459523