https://www.taxtmi.com/caselaws?id=464353 A non-resident's Mumbai office was treated as a preparatory or auxiliary fixed place of business, so it did not constitute a permanent establishment under Article 5(4)(e); income arising outside India was therefore not attributable to that office. The Revenue also could not raise, for the first time in a section 260A appeal, a challenge to the section 44BB presumptive income computation by disputing deduction of subcontractor payments, because the issue had not been raised before the Tribunal and no substantial question of law arose from the Tribunal's order. The High Court accordingly left the assessee's favourable findings undisturbed. en-us Thu, 14 Mar 2019 00:00:00 +0530 Fri, 24 Oct 2025 19:10:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464353 A non-resident's Mumbai office was treated as a preparatory or auxiliary fixed place of business, so it did not constitute a permanent establishment under Article 5(4)(e); income arising outside India was therefore not attributable to that office. The Revenue also could not raise, for the first time in a section 260A appeal, a challenge to the section 44BB presumptive income computation by disputing deduction of subcontractor payments, because the issue had not been raised before the Tribunal and no substantial question of law arose from the Tribunal's order. The High Court accordingly left the assessee's favourable findings undisturbed. Case-Laws Income Tax Thu, 14 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464353