Duration of each contract is to be taken into consideration separately for determining whether or not any PE was constituted

IN THE ITAT MUMBAI BENCH ‘L’ Deputy Commissioner of Income-tax, Circle 3(1), Mumbai versus J. Ray McDerrmott Eastern Hemisphere Ltd. IT APPEAL NO. 2089 (MUM.) OF 2011 [ASSESSMENT YEAR 1997-98] OCTOBER 12, 2012 ORDER R.S. Syal, Accountant Member This appeal by the Revenue arises out of the order passed by the Commissioner of Income-tax (Appeals) on 27.01.2011 in relation to the assessment year 1997-1998. 2. The only ground raised by the Revenue is against the direction of the learned CIT(A) to delete the amount received from contract work done in India ignoring the ...