2021 (3) TMI 333

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..... RDER We have heard both the parties. The applicant has filed the present application on 24/11/2020 wherein the following questions has been raised-; Q1. Whether on the facts and circumstances of the case, the amount received/receivable by the Applicant from Delhi Metro Rail Corporation Ltd. ('DMRC' or "Purchaser') under Purchase Order No. 62000425 dated May 08, 2018 in relation to o .....

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..... ant. The CIT has contended that there was a business connection of the applicant in India which constitutes Permanent Establishment and an appropriate profit needs to be attributable to the P.E. in India. Therefore, the transaction was designed for avoidance of tax. The Ld. A.R. clarified that the applicant was not liable for customs duty payment, as reported by the CIT. 3.  We do not find a .....

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