UK company found to have permanent establishment in India; 15% booking fees taxable.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Appellant, a UK company, had a business connection and PE in India u/s 9(1). 15% of booking fees were attributable to the PE in India, following earlier decisions for AY 2018-19 and 2019-20. Observations regarding appellant's status as a conduit entity were unnecessary and irrelevant. ITAT allowed appellant's appeal.....