https://www.taxtmi.com/caselaws?id=772711 A Mutual Agreement Procedure resolution under the India-USA tax treaty recorded no determination on whether the non-resident had a Permanent Establishment in India and dealt only with attribution of profits for specified years. Because the PE issue remained open and the later MAP communication had not been placed before the Tribunal, the earlier orders based on the assumption that prior-year findings continued to apply could not stand. The Tribunal's orders were therefore set aside and the matters remanded for fresh adjudication, with all rights and contentions left open. en-us Thu, 06 Mar 2025 00:00:00 +0530 Thu, 12 Jun 2025 07:21:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772711 A Mutual Agreement Procedure resolution under the India-USA tax treaty recorded no determination on whether the non-resident had a Permanent Establishment in India and dealt only with attribution of profits for specified years. Because the PE issue remained open and the later MAP communication had not been placed before the Tribunal, the earlier orders based on the assumption that prior-year findings continued to apply could not stand. The Tribunal's orders were therefore set aside and the matters remanded for fresh adjudication, with all rights and contentions left open. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772711