An appeal can be filed against the order of the Assessing Officer giving effect to the Mutual Agreement Procedure (MAP) resolution

Background:- The tax payer is a company incorporated in the United States of America (USA). It earned advertising and subscription revenues from sources in India during the year. Out of the said revenue, it also paid commission to an Indian agent.

The Assessing Officer (AO) assessed the income in the hands of the USA company holding that it has a permanent establishment in India and attributed 30% of net advertising revenue after allowing deduction of agency commission paid to the Indian agent. The tax payer p

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