ITAT Orders Re-adjudication Due to Arbitrary Profit Estimation

J.M. Voith SE & Co. KG Vs DCIT (ITAT Delhi) In the case of J.M. Voith SE & Co. KG Vs DCIT, the issue at hand pertains to the taxability of income earned from offshore supplies and the attribution of profit to a Permanent Establishment (PE) in India. The Assessee, J.M. Voith SE & Co. KG, contends that income from the supply of plants, equipment, and spares, which were manufactured and supplied from outside India, should not be taxable in India. Additionally, they argue that they do not have a PE in India. The crux of the matter revolves around a contract with Security Paper Mill (SP...