2023 (1) TMI 1244

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....sel. For the Respondent : Mr. Ved Jain with Mr. Nischay Kantoor, Advocates. ORDER [Physical Hearing/Hybrid Hearing (as per request)] 1. This appeal concerns Assessment Year (AY) 2009-2010, and is directed against the order dated 04.01.2022 passed by the Income Tax Appellate Tribunal [in short "Tribunal"]. 2. The appellant/revenue has proposed the following questions of law. ....

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.... D. Whether on the facts and circumstance of the case and in law, the Ld. ITAT has erred in holding that no income is liable to be attributed in India as Mitsui India Pvt. Ltd. (MIPL), the liaison office of the assessee, do not constitute a Dependent Agency Permanent Establishment (DAPE) of the assessee in India? E. Whether on the facts and circumstance of the case and in law, th....