2021 (9) TMI 1285

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....come Tax<br>HON&#39;BLE MR. JUSTICE MANMOHAN AND HON&#39;BLE MR. JUSTICE NAVIN CHAWLA Appellant Through : Mr. Sanjay Kumar, Advocate with Ms. Easha Kadiyan, Advocate. Respondent Through : Mr. Deepak Chopra, Advocate and Mr. Ankul Goyal, Advocate. MANMOHAN, J. (Oral) The hearing has been done by way of video conferencing. 1. Present appeals have been filed challenging the order dated....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s a PE, in the form of M/s L.G. Electronics India Ltd. under Article 5(1) & 5(2) of DTAA between India and Korea? B. Whether on facts and in the circumstances of the case, the Ld. ITAT erred in law in holding that no income is attributable to the assessee PE in India? C. Whether on facts and in the circumstances of the case, the Ld. ITAT erred in law in setting aside re-opening o....