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.

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