Taxation under Section 44BB upheld over Section 9(1)(vii) r.w.s. 44DA; 2% offshore profit attribution accepted

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....ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin.....