In the result ITA No.1489/Kol/11 is partly allowed
Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am] Assessment Year : 2007-08
section 115A of the Act. This contention of the Assessee was however, without prejudice to the contention that the Assessee does not have a PE in India in terms of the DTAA and its entire income is not chargeable to tax. 28. Issue of claims made by the Assessee without revising the return On the above issue, the Assessee submitted