2018 (10) TMI 139 - SCH - Income Tax

Income accrued in India - Existence of Permanent establishment (PE) so as to attract the provisions of Section 9 - Income accrued in India - income directly or indirectly attributable to the branches/offices is not taxable in India - DTAA between India and Japan - Held that - This special leave petition is disposed of in the light of our order titled Director of Income Tax ( International Taxation) 2 New Delhi v. M/s. Mitsui and Company 2018 (7) TMI 141 - SUPREME COURT OF INDIA

Summary

The Supreme Court condoned the delay and disposed of the special leave petition based on a previous order. The question of law remains open, and any pending application is also disposed of.