Non-resident French shipping company not to pay tax on business income unless it is having PE in India

IN THE ITAT MUMBAI BENCH ‘L’ Delmas France S.A. Versus Assistant Director of Income-tax (International Taxation) IT Appeal No. 8991 (Mum.) of 2010 [Assessment year 2007-08] January 16, 2013 ORDER Dinesh Kumar Agarwal, Judicial Member – This appeal preferred by the assessee is directed against the assessment order dtd. 25-10-2010 for the A.Y. 2007-08 passed by the A.O. u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act) after considering the directions dtd. 28-9-2010 of the Dispute Resolution Panel – I, Mumbai. 2. Briefly stated facts of the...