MARIAPPAN AUSTIN PRAKASH,BENGALURU, KANRNATAKA vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTL TXN CIRCLE, VISAKHAPATNAM
ITA 89/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2022-23
Section 142(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 195Section 9(1)(i)
permanent establishment as\nper Article 5 of the India-UAE DTAA being determined in the case of the\nAppellant, and more so when the Tax Residency Certificate from the\nFederal Tax Authority of the UAE and Form 10F, on the basis of which\nthe residential status of the Appellant was determined as that of a 'non-\nresident', were placed
