9911796707
TMI Blog2022 (9) TMI 311X X X X Extracts X X X X X X X X Extracts X X X X ..... with Mr. Shlok Chandra, Junior Standing Counsel for Revenue. Respondent Through: None J U D G M E N T MANMOHAN, J (Oral): 1. Present Income Tax Appeal has been filed challenging the order dated 9th November, 2020 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 6499/Del./2012 for the Assessment Year 2006-07. 2. Learned counsel for the Appellant-Revenue states that the ITAT has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ok reveals that the ITAT has held that since no guidelines are available as to how much income of the Assessee-Respondent be reasonably attributable to India, the same has to be determined on the basis of the facts and judicial precedents. 6. In the present case, the ITAT and CIT(A) have held that out of several activities, the activities of Calleo Distribution Technologies Private Limited in Ind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e revenue to the Respondent's PE in India. In fact, the Appellant has not brought on record anything which differentiates the facts of this case with that of Galileo International (Supra). 9. Consequently, no substantial question of law arises for consideration in the present appeal and the same is dismissed. 10. This Court clarifies that in the present proceeding, it cannot comment on the order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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