Determination of PE when Research of product produced by Non-Resident Company situated in USA is done by its branch office in India

RELEVANT PARAGRAPH All these appeals, filed by the assessee and the revenue, are directed against the common order dated 04.02.2005 passed by the Ld. CIT(A), pertaining to the assessment years 1997- 98, 1999- 2000, 2000- 01 and 2001- 02. 2. These appeals were heard along with ITA No. 4925/Del/2004 filed by the assessee for the A.Y. 1998- 99 in respect of which a separate order has already been passed. 3. In connection with the aforesaid appeals filed by the revenue, the assessee had also filed cross objections numbered as Co. Nos. 345 to 348/Del/2007, which have already been disposed of by a s...