https://www.taxtmi.com/caselaws?id=764695 ITAT Delhi held that a UK-incorporated company had business connection and PE in India under section 9(1), with 15% of booking fees attributable to Indian PE, following precedent from earlier assessment years. The tribunal rejected revenue's conduit entity argument as irrelevant and unsupported by evidence, noting this determination was unnecessary for deciding Indian tax liability. The assessee's appeal was allowed, with the tribunal finding the conduit company observations by AO were based on insufficient material and irrelevant to the core taxability issue. en-us Mon, 30 Dec 2024 00:00:00 +0530 Wed, 15 Jan 2025 13:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764695 ITAT Delhi held that a UK-incorporated company had business connection and PE in India under section 9(1), with 15% of booking fees attributable to Indian PE, following precedent from earlier assessment years. The tribunal rejected revenue's conduit entity argument as irrelevant and unsupported by evidence, noting this determination was unnecessary for deciding Indian tax liability. The assessee's appeal was allowed, with the tribunal finding the conduit company observations by AO were based on insufficient material and irrelevant to the core taxability issue. Case-Laws Income Tax Mon, 30 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764695