Indian subsidiary operating in independent manner doesn’t constitute PE

Gemological Institute of America Vs ACIT (ITAT Mumbai) ITAT Mumbai held that the Indian Subsidiary operating in an independent manner doesn’t constitute as a ‘Permanent Establishment (PE)‘ in India and hence income of the assessee is not allowable to be taxed in India. Facts- The assessee has preferred the present appeal contesting that AO/ DRP have erred in assessing the total income of the Appellant at Rs. 4,30,87,11,440/- as against the returned income of Rs. 3,78,49,90,577/- thereby determining the tax liability of Rs. 1,97,08,89,750/- against the refund claimed of Rs. 3,01,1...