What is IT Solution Inc. v. ADIT authority for?

A Permanent Establishment (PE) under a tax treaty requires a distinct 'situs' and a 'fixed place of business'. This definition involves two essential conditions: the existence of a 'place of business' (facility, premises, machinery, or equipment) and that this place must be 'fixed'.

How many judgments cite IT Solution Inc. v. ADIT?

73 judgments on BharatTax cite IT Solution Inc. v. ADIT (86 Taxmann.com 240), spanning 2018 to 2026.

Which sections of the Income Tax Act does IT Solution Inc. v. ADIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 144C(13), Section 142(1), Section 234B, Section 234C, Section 234D.

IT Solution Inc. v. ADIT (86 Taxmann.com 240)

GENERAL REINSURANCE CORPORATION,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(3)(2), MUMBAI

In the result, the Ground No

ITA 1817/MUM/2025[2022-23]Status: DisposedITAT Mumbai07 Jan 2026AY 2022-23

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) General Reinsurance Corporation Acit (International Taxation), 1209, Orange Street Delaware, Vs Circle -2(3)(2), Mumbai Room No. 610, 6Th Floor, Kautilya Wilmington, United States, 19801 Usa Bhavan, G Block, Bandrakurla Complex, Bandra (East), [Pan:Aahcg8162B] Mumbai-400051. Appellant / Assessee Respondent / Revenue

Section 143(2)Section 143(3)Section 254(1)Section 9(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Physical hearing) General Reinsurance Corporation ACIT (International Taxation), 1209, Orange Street Delaware, Vs Circle -2(3)(2), Mumbai Room No. 610, 6th Floor, Kautilya Wilmington, United States, 19801 USA Bhavan, G Block, BandraKurla Complex, Bandra (East), [PAN:AAHCG8162B] Mumbai-400051. Appellant / Assessee Respondent / Revenue Assessee by Shri Madhur Agarwal Advocate Revenue by Shri Krishna Kumar, Sr. DR Date of institution of appeal 18.03.2025 Date of hearing 16.10…

SAIC MOTOR CORPORATION LTD,CHINA vs. DCIT,INTERNATIONAL TAX, GURGAON

In the result, the appeal of the assessee is partly allowed

ITA 1191/DEL/2025[2022-23]Status: DisposedITAT Delhi07 Jan 2026AY 2022-23

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] Saic Motor Corporation Assistant Commissioner Of Income Limited, Tax, International Taxation, Gurgaon, Room No.509, Building No.1, Vs Hsiidc Building, Vanijya Nikunj, Tower No.563, Songtao Road, Udyog Vihar, Phase-V, Gurgaon, Pilot Free Trade Zone, Sanghai, Haryana-122001 China, Pan-Abfcs0870H Assessee Revenue Assessee By Shri Ajay Vohra, Sr. Adv. Shri Kunal Pandey, Adv. Revenue By Shri Rohit Garg, Cit-Dr Date Of Hearing 10.10.2025 Date Of Pronouncement 07.01.2026 Order

Section 142(1)Section 143(2)Section 143(3)Section 144CSection 153(1)

…ITA No.- 1191/Del/2025 SAIC Motor Corpora"on Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI VIMAL KUMAR, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER [Assessment Year: 2022-23] SAIC Motor Corporation Assistant Commissioner of Income Limited, Tax, International Taxation, Gurgaon, Room No.509, Building No.1, Vs HSIIDC Building, Vanijya Nikunj, Tower No.563, Songtao Road, Udyog Vihar, Phase-V, Gurgaon, Pilot Free Trade Zone, Sanghai, Haryana-122001 China, PAN-ABFCS0870H Assessee Revenue Assessee by Shri Ajay Vohra, Sr. Adv. Shri Kunal Pandey, Adv. Revenue by Shr…