In the result, the appeal of the Revenue is dismissed
Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No. 2999/Ahd/2014 िनधा"रण वष"/A.Y.:2010-11 Assistant Commissioner Vs. M/S. Ramdev Chemical Of Income Tax, Bharuch Industries, 3441-B, Gidc, Circle - Bharuch Industrial Estate Ankleshwar Pan: Aacfr3839A अपीलाथ" Appellant ""यथ"/Respondent
permanent establishment in India. Therefore, income in the form of commission paid by the assessee was also not arise or accrued to those non- resident through or from any asset or sources of income in India or through transfer of capital asset situated in India. In the facts and circumstances, we are of considered view that provisions of section