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TMI Blog2021 (9) TMI 1374X X X X Extracts X X X X X X X X Extracts X X X X ..... s and Permanent Establishment as defined under Article 5 (2) (c) of the Double Taxation Avoidance Agreement between India and UAE? - appeal of the revenue mainly relates to the provisions of Article 5(2)(c) with regard to treating of project office as fixed place PE, the preparatory and auxiliary functions as per Article 5(3)(e) and treating the assessee as installation PE under Article 5(2)(h) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 14/Del/2018 - - - Dated:- 22-9-2021 - SH. KUL BHARAT, JUDICIAL MEMBER AND DR. B. R. R. KUMAR, ACCOUNTANT MEMBER For the Assessee : Sh. Amit Arora, Adv. For the Revenue : Sh. Sunil Kumar, CIT DR ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the revenue against the order of ld. CIT (A)-43, New Delhi dated 20.12.2017. 2. Followi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... manent Establishment under Article 5 (2) (h) of the Double Taxation Avoidance Agreement between India and UAE. (iv) Whether, on the facts and in the circumstances of the case, the Ld. CIT (A) erred in holding that M/s Arcadia Shipping Ltd was not a Dependent Agent Permanent Establishment of the assessee under Article 5 (4) of the Double Taxation Avoidance Agreement between India and UAE. (v) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the PE of the assessee. 3. The appeal of the revenue mainly relates to the provisions of Article 5(2)(c) with regard to treating of project office as fixed place PE, the preparatory and auxiliary functions as per Article 5(3)(e) and treating the assessee as installation PE under Article 5(2)(h) of DTAA between India and UAE. 4. At the outset, the counsels brought to the notice of the benc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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