https://www.taxtmi.com/caselaws?id=777608 ITAT Del. AT held for the taxpayer that two individuals whose travel was reimbursed were employees of the associated enterprise (EPI), not of the appellant, and thus their presence in India is irrelevant to computing the appellant's stay under Article 5(3)(b) of the India-Korea DTAA. The tribunal found the Department's determination of a deemed PE was based on conjecture and reversed the Assessing Officer's additions confirmed by the CIT(A), deleting those adjustments and deciding in favour of the assessee. en-us Thu, 28 Aug 2025 00:00:00 +0530 Tue, 02 Sep 2025 08:01:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777608 ITAT Del. AT held for the taxpayer that two individuals whose travel was reimbursed were employees of the associated enterprise (EPI), not of the appellant, and thus their presence in India is irrelevant to computing the appellant's stay under Article 5(3)(b) of the India-Korea DTAA. The tribunal found the Department's determination of a deemed PE was based on conjecture and reversed the Assessing Officer's additions confirmed by the CIT(A), deleting those adjustments and deciding in favour of the assessee. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777608