9911796707
TMI Blog2012 (11) TMI 765X X X X Extracts X X X X X X X X Extracts X X X X ..... rrying out, in addition to assembly, installation of certain items, and that project and other activities were carried out in India for a period less than 9 months. Held that:- ITAT had remanded the matter back for ascertaning the facts - in the event, it is held that the assessee had a permanent establishment during the relevant assessment year in India, it goes without saying that the Assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Application for condonation of delay in preferring the appeal and, although day-to-day delay has not been explained, but, having regard to the overall situation prevalent, we think that a case has been made out for condonation of delay. We, accordingly, allow the Application. 2. Before ITAT, respondent / assessee held out that it s income is not taxable in India, inasmuch as, it is a foreign ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tter in favour of the respondent / assessee. Instead, it remitted back the matter to the Assessing Authority for the purpose of ascertaining, whether, in fact, such assertion on the part of the assessee is true or not. The Tribunal, thereafter, directed that, upon ascertainment of the truth and substance of such assertion of the assessee, the matter must proceed. 3. In the circumstances, we find ..... X X X X Extracts X X X X X X X X Extracts X X X X
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