ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO
In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A
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