2011 (6) TMI 1027

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....RDER PER K.G. BANSAL,AM: In this appeal, the assessee has challenged the assessment order in respect of the finding about the existence of permanent establishment (PE for short) and attribution of profit to the PE. Before us, the learned counsel for the assessee submitted that detailed submissions were made before the Dispute Resolution Panel ("DRP" for short) on both the issues, but it has co....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ost @10% as per DTAA relying on the decision of Advance Ruling and ITAT decision. In view of the reasons discussed we do not find any fault with the draft order of the Assessing Officer and hence no directions are being issued." It is submitted that the order does not deal with the submissions of the assessee in a speaking manner and, therefore, the same has been passed ignoring the principle....