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    <title>2025 (5) TMI 508 - ITAT DELHI</title>
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    <description>ITAT Delhi held that addition of business income on account of fixed place permanent establishment (PE) taxed at 40% surcharge was not sustainable. The Tribunal followed its coordinate bench decision in assessee&#039;s own case from previous year, finding no change in facts and circumstances. The addition made by Assessing Officer regarding PE taxation was deleted, and grounds raised by assessee were allowed. The decision favored the assessee based on consistent application of previous ruling on PE existence and profit attribution.</description>
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      <link>https://www.taxtmi.com/caselaws?id=770236</link>
      <description>ITAT Delhi held that addition of business income on account of fixed place permanent establishment (PE) taxed at 40% surcharge was not sustainable. The Tribunal followed its coordinate bench decision in assessee&#039;s own case from previous year, finding no change in facts and circumstances. The addition made by Assessing Officer regarding PE taxation was deleted, and grounds raised by assessee were allowed. The decision favored the assessee based on consistent application of previous ruling on PE existence and profit attribution.</description>
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