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TMI Blog2019 (1) TMI 2040X X X X Extracts X X X X X X X X Extracts X X X X ..... zerland DTAA @ 10% or payment of interest is inextricably connected with the company s permanent establishment in India and is therefore assessable as per Article 7 of the DTAA? - HELD THAT:- Revenue very fairly states that this issue stands concluded against the Revenue and in favour of the Respondent Assessee by the decision of this Court in Director of Income Tax (International Taxation) v/s. C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bunal (the Tribunal). The common impugned order dated 20th February, 2015 is in respect of Assessment Years 200506, 200607, 200708, 200809 and 200910. These two appeal relates to Assessment Years 200506 and 200607. 2 Revenue urges the following questions of law, for our consideration: "(a) Whether on the facts and circumstances of the case and in law, the Trib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Tejveer Singh, learned Counsel for the Revenue very fairly states that this issue stands concluded against the Revenue and in favour of the Respondent Assessee by the decision of this Court in Director of Income Tax (International Taxation) v/s. Credit Agricole Indosuez 372 ITR 102 and CIT v/s. Tech. Mahindra Ltd., 397 ITR 748. (iii) In view of the above, the question as framed does not gi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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