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No Fixed Place PE in India as Customer Premises Were Not at Foreign Company’s Disposal: ITAT Delhi
Case Law Details
- Case Name
- Imax Corporation Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2022-23
- Courts
- All ITAT, ITAT Delhi
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Imax Corporation Vs ACIT (ITAT Delhi)
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) allowed the appeal filed by a Canadian company engaged in developing, selling, and leasing large-format theatre systems, along with installation and related support services. The dispute arose from the assessment order passed under Sections 143(3) read with 144C(13) of the Income Tax Act, wherein the Assessing Officer (AO) alleged that the company had a Permanent Establishment (PE) in India and attributed income to such PE.
The assessee had entered into agreements with Indian cus...
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