TaxTMI 
TaxTMI 
2022 (2) TMI 1287
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....Kumar, Sr. DR. ORDER PER N. K. BILLAIYA, AM: This appeal filed by the assessee is preferred against the order of the CIT(A)-42, New Delhi dated 13.08.2018 for A.Y. 2014-15. 2. Ground No.1 is of general in nature and needs no adjudication. 3. Ground No.2 is, as stated, is academic in nature and on such statement we do not find it necessary to adjudicate the form ground for academic interest ....
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....served as under :- "8.6 Though facts of the case for this year are slightly different from those of earlier years as this year there are two contracts namely BS-02 and CS-01 as compared to only one contract in earlier years. However, in sum and substance these are similar. Therefore, conclusions drawn in earlier years on the basis of analysis of BS-02 contract may apply to both the contracts for....
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....ssesee's case and accordingly, held that BTIN is the PE of the assessee in India in respect of contract BS02 & CS01 with the DMRC. Hence, the AO concluded that the income in respect of the DMRC contract BS02 & CS 01 needs to be attributed to the PE in India." 9. The CIT(A) further extracted the findings of the DRP for A.Y.2011-12 based on the contract between the assessee and DMRC at para-7.7 of....
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....factured at overseas manufacturing facility of the appellant and sale of equipment has occurred outside India and payment has also been received by the appellant and outside India. 38. We find that during the DRP proceedings, the DRP was misdirected in considering the contract RS 02. This contract is between BTIN Bombardier Transportation, Germany and DMRC and for this contract, Bombardier Trans....