MIPL is not a Dependent Agency Permanent Establishment of Mitsui & Co.

Mitsui & Co. Ltd. Vs DDIT (International Taxation) (ITAT Delhi) Since the lower authorities following the orders of the preceding years have held that M/s. Mitsui & Co. Ltd. has been constituted as Dependent Agent PE of the assessee company in India, therefore, following the consistent decisions of the Tribunal in assessee’s own case in the preceding assessment years and in absence of any contrary material brought to our notice against the decision of the Tribunal we hold that MIPL is not a Dependent Agency Permanent Establishment (DAPE) of the assessee. We find following the above d...