https://www.taxtmi.com/caselaws?id=459548 Attribution of offshore-supply receipts required fresh examination because the existence of a permanent establishment in India depended on the complete contractual framework, the scope of work and the allocation of responsibilities among consortium members. As the relevant contracts had not been fully examined, the tribunal held that the matter could not be decided mechanically on prior assessments and restored the issue for de novo adjudication. The Assessing Officer was directed to reconsider the contracts and surrounding facts after giving the assessee an opportunity to be heard, so the additions were not finally sustained at this stage. en-us Wed, 17 Jan 2024 00:00:00 +0530 Wed, 18 Dec 2024 10:53:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459548 Attribution of offshore-supply receipts required fresh examination because the existence of a permanent establishment in India depended on the complete contractual framework, the scope of work and the allocation of responsibilities among consortium members. As the relevant contracts had not been fully examined, the tribunal held that the matter could not be decided mechanically on prior assessments and restored the issue for de novo adjudication. The Assessing Officer was directed to reconsider the contracts and surrounding facts after giving the assessee an opportunity to be heard, so the additions were not finally sustained at this stage. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459548