PE in India not establishes merely because Assessee offered its income for tax in India

Linklaters Vs Dy. DIT (ITAT Mumbai)

Though the lower authorities had rejected the claim of the assessee that it did not have any ‘PE’ during the period November, 2008 to March, 2009, and rather concluded that the assessee had a ‘PE’ in India during the year under consideration, however we find that no concrete reasoning which could justify dislodging of the claim of the assessee and support the view so arrived at by the lower authorities is discernible from the respective orders of the lower authorities. That as a matter of fact, the orders of

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