Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

144C of the Act in respect of AY 2008-09. 4. By an order dated 24th February, 2015, ITA Nos. 666/2014, 667/2014 and 673/2014 were admitted and the following questions of law were framed:- "(i). Whether the Tribunal erred in concluding that the Appellant had a Permanent Establishment (PE) within the meaning of Article 5 of the Double Taxation Avoidance