‘Force of attraction rule’ to tax income not directly connected to PE in India – ITAT

IN THE ITAT MUMBAI BENCH ‘L’ Linklaters & Paines Versus Income-tax Officer, (International Taxation) M.A. NO. 223 (MUM.) OF 2011 IT APPEAL NOs. 2896 & 5085 (MUM.) OF 2003 [ASSESSMENT YEAR 1995-96] DECEMBER 19, 2012 ORDER P.M. Jagtap, Accountant Member  By this miscellaneous application, the assessee is seeking rectification of mistake alleged to have crept in the common order of the Tribunal dated 16th July, 2010 passed in ITA No. 4896/Mum/2003 and 5085/Mum/2003. 2. The learned counsel for the assessee submitted that one of the issues raised by the Revenu...