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Addition of Offshore Supply Income to PE in India on account of loss Unjustified
Case Law Details
- Case Name
- Hitachi Ltd Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Delhi
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Hitachi Ltd Vs ACIT (ITAT Delhi)
ITAT Delhi held that addition on account of attributing income from offshore supplies to permanent establishment in India unjustified in case of loss.
Facts- The assessee filed its return of income for the assessment year under appeal declaring total income of Rs. 45,27,08,220/-. The case was selected for complete scrutiny. In response to the statutory notices issued by the Assessing Officer (AO), the assessee filed the reply regarding details of off-shore supply made by the assessee during the year under consideration. After considering the su...
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