levied on income
arising from services rendered in India by India PE,
whereas, appeal has been admitted before the High Court
on issue of total ... receipts pertaining to India in hands of
Indian PE?"
3. The issue concerns the penalty imposed by the
assessing officer against the respondent - assessee
levied on income
arising from services rendered in India by India PE,
whereas, appeal has been admitted before the High Court
on issue of total ... receipts pertaining to India in hands of
Indian PE?"
3. The issue concerns the penalty imposed by the
assessing officer against the respondent - assessee
levied on income
arising from services rendered in India by India PE,
whereas, appeal has been admitted before the High Court
on issue of total ... receipts pertaining to India in hands of
Indian PE?"
3. The issue concerns the penalty imposed by the
assessing officer against the respondent - assessee
levied on income
arising from services rendered in India by India PE,
whereas, appeal has been admitted before the High Court
on issue of total ... receipts pertaining to India in hands of
Indian PE?"
3. The issue concerns the penalty imposed by the
assessing officer against the respondent - assessee
levied on income
arising from services rendered in India by India PE,
whereas, appeal has been admitted before the High Court
on issue of total ... receipts pertaining to India in hands of
Indian PE?"
3. The issue concerns the penalty imposed by the
assessing officer against the respondent - assessee
erred in holding that the assessee
company does not have any PE in India within the meaning of
Article
discharged the burden
of proving that the appellant had a PE in India?
3. The impugned order of the Tribunal restored the issue
of permanent
having projects in India
was not attributable to the profits of the PE as per
Article 7(1) of the India-UK DTAA
leviable in this case without taking into consideration the
existence of PE in India and thus liable to pay advance tax?"
4 Learned Counsel
discharged the burden
of proving that the appellant had a PE in India?
3. The impugned order of the Tribunal restored the issue
of permanent
