Tribunal Overturns DRP's Assessment; Orders Re-evaluation of Dependent Agent Permanent Establishment in India.

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....Accrual of income in India - existence of DAPE - PE in India or not? - The ITAT previously ruled in favor of the Assessee regarding the existence of a fixed place PE. However, the DRP's directions in the present assessment were based on a misunderstanding of the previous decisions. - The Tribunal sets aside the assessment order and directs the DRP to re-examine the issue of the existence of DAPE, providing an opportunity for the Assessee to be heard.....