2021 (9) TMI 1285

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....CE MANMOHAN AND HON'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 20th October, 2020 passed by the Income Ta....

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....d. 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 of assessment under Section 147 of the Act by the AO? 3. Learned c....