NATIONAL PETROLEUM CONSTRUCTION COMPANY vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(2) INTERNATIONAL TAXATION NEW DELHI
Appeal is hereby allowed to the extent
C.A. No.-004964-004964 - 2022Supreme Court29 Jul 2022
Bench: HON'BLE MS. JUSTICE INDIRA BANERJEE
Section 143(1)Section 197
195 and at the
stage of section 197 proceedings, the question of existence of
permanent establishment is not required to be gone into.
Therefore, having regard to the aforesaid provision, we cannot
direct the Revenue to hold that the petitioner does not have a PE
and give the consequent effect of such finding while deciding an
application under Section
