In the absence of PE, Business profit of eBay from India Specific websites not taxable

IN THE ITAT MUMBAI BENCH ‘L’ eBay International AG versus Assistant Director of Income-tax, Range – 3(2) IT APPEAL NOs. 6784 & 7046 (MUM.) OF 2010 [ASSESSMENT YEAR 2006-07] SEPTEMBER 21, 2012 ORDER R.S. Syal, Accountant Member These two cross appeals – one by the assessee and other by the Revenue emanate from the order passed by the CIT (A) on 12.7.2010 in relation to assessment year 2006-07. 2. Briefly stated the facts of the case are that the assessee is a company incorporated under the law of Switzerland and is a tax resident of Switzerland. The ...