Taxability of receipts from offshore supplies and onshore ...
Court Overturns Tax Assessment of Rs.54.22 Crores Attributed to Permanent Establishment Due to Factual Inconsistencies and Oversight.
April 26, 2023
Case Laws Income Tax AT
Taxability of receipts from offshore supplies and onshore services - Though, the global accounts of the assessee are very much available with the Assessing Officer, however, while finalizing the assessment in pursuance to the directions of learned DRP, the Assessing Officer has not consider the global profit and straightway attributed 25% of Rs.54.22 crores to the PE. Thus due to factual inconsistencies and non-consideration of facts on record by learned DRP, the impugned assessment order deserves to be set aside. - AT
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