ITAT Delhi: Sales Commission Not Taxable—No PE, No Business Connection

LM Wind Power AS Vs ACIT (ITAT Delhi)

Sales Commission Not Taxable in India – No PE, No Business Connection; Wrong Agreements Used by AO; Royalty u/s 115A Accepted

In LM Wind Power AS Vs ACIT Intl. Tax 2(2)(1), Delhi – ITA No.4280/Del/2024 for AY 2020-21 (Order dated 21.11.2025), the Denmark-based Assessee, a global sales support entity of the LM Group, challenged the addition of ₹16.97 crore out of ₹69.28 crore of sales c

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