UK company found to have permanent establishment in India; 15% booking fees taxable.

Appellant, a UK company, had a business connection and PE in India u/s 9(1). 15% of booking fees were attributable to the PE in India, following earlier decisions for AY 2018-19 and 2019-20. Observations regarding appellant's status as a conduit entity were unnecessary and irrelevant. ITAT allowed appellant's appeal. .....

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