2017 (8) TMI 1638

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... y way of payment to the Indian entity for marketing services? - Was the AO justified in adopting a different rate of attribution contrary to Article 7 of the Indo-China DTAA? - HELD THAT:- The learned counsel for the parties are permitted to file additional documents/papers which are part of the assessment record or were filed before the ITAT within eight weeks. List in due course. - ITA 297/ .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ssessee has a Permanent Establishment ( PE ) in India, could any income be attributed to such PE on account of offshore supplies? (ii) If the answer to the question (i) above is in the affirmative what should be the rate of attribution? (iii) Is the Assessee entitled to adjustment of the expenses already incurred by it by way of payment to the Indian entity for marketing services? 4. For .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X