SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM
In the result, the appeals of the assessees in ITA Nos
ITA 39/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11
Bench: S/Shri Chandra Poojari, Am&George George K., Jm
permanent establishment under
the double taxation avoidance agreement and as ruled in the second decision, the 15
I.T.A. Nos.37 to 49/Coch/2016
concept of revenue neutral cannot be applied to the case of the assessee since all
the concerns of the assessee group were doing their business independently having
no access with each other and the profit the assessee otherwise would
