In the result ITA number 5584/Del/2013 filed by the assessee for assessment year
Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi
permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental