2022 (9) TMI 311

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....nding Counsel for the Revenue along with Mr. Shlok Chandra, Junior Standing Counsel for Revenue. Respondent Through: None J U D G M E N T MANMOHAN, J (Oral): 1. Present Income Tax Appeal has been filed challenging the order dated 9th November, 2020 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 6499/Del./2012 for the Assessment Year 2006-07. 2. Learned counsel for t....

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....h the facts and law. 5. A perusal of the paper book reveals that the ITAT has held that since no guidelines are available as to how much income of the Assessee-Respondent be reasonably attributable to India, the same has to be determined on the basis of the facts and judicial precedents. 6. In the present case, the ITAT and CIT(A) have held that out of several activities, the activities of C....