In absence of PE in India No tax on money received by IBM Philippines in the course of their business

Advocate Akhilesh Kumar Sah DCIT, International Taxation Vs IBM India Pvt. Ltd (ITAT Bangalore) IBM India Pvt. Ltd  case: IBM Philippines received the monies in the course of their business and did not have PE in India and therefore the receipt in question could not be brought to tax Case in brief: In DCIT, International Taxation vs. IBM India Pvt. Ltd [IT(IT)A Nos.1288, 1291, 1294, 1297, 1300, 1303 & 1306/Bang/2017, A.Y. 2009-10 to 2015-16, decided on 16.11.2018], there were appeals by the DCIT (International Taxation) Circle 1 (1), Bangalore, against the order dated 31.3.2017 of CIT(Ap...