2 results for “section 68”+ Permanent Establishmentclear
Sorted by relevance
Key Topics
In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
permanent establishment in India and there has to be territorial nexus with the earning of the income, no services are rendered in India and neither the same is received in India. Therefore, no income accrued in India. Explanation to Sec. 9 inserted by the Finance Act, 2010 is not applicable as all the payments were made when the Finance