Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited
ITTA/667/2014HC Telangana29 Jan 2015
Section 143(3)Section 147Section 260A
234B of the Act?‖
7.
The principal controversy involved in these appeals (ITA Nos.
669/2014, 671/2014, 672/2014 and 689/2014) is whether the Assessee, a
tax resident of United States of America (USA), has a Permanent
Establishment (hereafter 'PE') in India and consequently, is chargeable to
tax under the Act in respect of its business income attributable