https://www.taxtmi.com/caselaws?id=790623 Attribution of income to the Indian branch and project offices, including the transfer pricing adjustments, was directed to be examined afresh because the disputes for the year overlapped substantially with earlier years and raised similar factual and legal questions. The Tribunal noted that the branch office was an expanded continuation of the liaison office and constituted a permanent establishment in India, but also recorded the assessee's contention that the branch functioned only for the machinery division. On that basis, the Assessing Officer was asked to reconsider the matter de novo after evaluating the assessee's submissions on merits. en-us Thu, 23 Apr 2026 00:00:00 +0530 Mon, 27 Apr 2026 15:03:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790623 Attribution of income to the Indian branch and project offices, including the transfer pricing adjustments, was directed to be examined afresh because the disputes for the year overlapped substantially with earlier years and raised similar factual and legal questions. The Tribunal noted that the branch office was an expanded continuation of the liaison office and constituted a permanent establishment in India, but also recorded the assessee's contention that the branch functioned only for the machinery division. On that basis, the Assessing Officer was asked to reconsider the matter de novo after evaluating the assessee's submissions on merits. Case-Laws Income Tax Thu, 23 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790623