Addition of Offshore Supply Income to PE in India on account of loss Unjustified

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 submissions of the ...