2018 (3) TMI 477

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....tes. ORDER Admit. The question urged in this appeal for consideration is:- "(1) Whether the assessee has constituted the permanent establishment (PE) so as to attract the provisions of Section 9 of the Income Tax Act, 1961?" The impugned order itself discloses that the Income Tax Appellate Tribunal (ITAT) has followed its previous decisions of other years. One of those decisions was carried i....

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.... by him to specific queries. The Court is unable to be persuaded that the ITAT erred in its conclusion that the evidence produced by the AO does not show that the LOs of the Assessee carried on any activity which was not incidental and auxiliary in nature. 19. It is urged by Mr. Jain that the ITAT had merely gone by the fact that the Reserve Bank of India ("RBI") had not found the Assessee to b....