2020 (2) TMI 1733

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....ax<br>MR. VIPIN SANGHI AND MR. SANJEEV NARULA JJ. Appellant Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Amit Shrivastava and Mr. Ankul, Advs. &nbsp; Respondent Through: Mr. Raghvendra Singh and Ms. Easha Kadian, Advs. &nbsp; O R D E R We have heard learned counsels for the parties. The following questions of law arise and are framed in the present appeal for our consideration: ....

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....8 as follows: "88. In view of above facts, we set aside all the appeals of the assessee back to the file of the learned dispute resolution panel with a direction to first ascertain the fact about the admission of the assessee with respect to acceptance of the assessee of the existence of the permanent establishment. If it is found that there is an admission on part of the assessee about t....

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....s, with respect to the existence of the permanent establishment as well as the profit attribution thereto would be open before the learned dispute resolution panel." Mr. Vohra, learned senior counsel for the appellant has submitted that the Tribunal being the last fact finding authority should have examined, firstly, the issue whether there was any concession made by the appellant with regard t....