Taxability Of Income Earned By A Resident Assessee From Russia Through Its PE

RELEVANT PARAGRAPHS: 9. We have considered the rival submissions and also perused the relevant material on record. It is observed that a similar issue was involved in assessee’s own case for the earlier years i.e. AY 1991-92, 92-93 & 93-94 and the Tribunal vide its consolidated order dated 12.6.1998 has decided the same in favour of the assessee for the said years following the decision of Special Bench of ITAT in the case of P.A.V.L. Kulandayan Chettiar (supra) which has been subsequently affirmed by the Hon’ble Supreme Court. The learned DR, however, has made an attempt to di...