Court Upholds 15% Revenue Attribution to Indian Permanent Establishment; Rule 27 Invoked to Challenge CIT(A) Decision.

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....Attribution of 15% Revenue to the PE in India - invocation of Rule 27 for challenging the decision of the CIT (A) - Since no guidelines are available as to how much should income be reasonably attributable to India, the same has to be determined on the basis of the facts of the case and judicial precedents. - the ld. CIT(A) rightly attributed 15% of the Revenue - AT....