directing the A.O. to exclude the profits from Oman Branch
and Qatar Branch for tax purposes in India, holding that as the assessee ... been carrying on business through a permanent Establishment in Oman and
Qatar and as the income from the aforesaid Branch in Oman and Qatar
Jurisdictional High Court
in the case of CIT vs Qatar Airways reported in 332 ITR 253 (Bom), the
same decision was rendered. The facts
directing the A.O. to exclude the profits from Oman Branch
and Qatar Branch for tax purposes in India, holding that as the assessee ... been carrying on business through a permanent Establishment in Oman and
Qatar and as the income from the aforesaid Branch in Oman and Qatar
Shapoorji Pallonji Barwa City Real Estate 1,00,86,12,280
Mid Qatar WLL Company, WLL
4. The TPO noted that the Assessee had raised ... length
Pallonji Mid guarantee commission in
Qatar WLL this case is held to be the
average of the arm's
length guarantee
commissions charged
Shapoorji Pallonji Barwa City Real Estate 1,00,86,12,280
Mid Qatar WLL Company, WLL
4. The TPO noted that the Assessee had raised ... length
Pallonji Mid guarantee commission in
Qatar WLL this case is held to be the
average of the arm's
length guarantee
commissions charged
Shapoorji Pallonji Barwa City Real Estate 1,00,86,12,280
Mid Qatar WLL Company, WLL
4. The TPO noted that the Assessee had raised ... length
Pallonji Mid guarantee commission in
Qatar WLL this case is held to be the
average of the arm's
length guarantee
commissions charged
Shapoorji Pallonji Barwa City Real Estate 1,00,86,12,280
Mid Qatar WLL Company, WLL
4. The TPO noted that the Assessee had raised ... length
Pallonji Mid guarantee commission in
Qatar WLL this case is held to be the
average of the arm's
length guarantee
commissions charged
establishment in India under Article 5 read with Article 7 of India-
Qatar DTAA.
v. On the facts and in the circumstances of the case ... permanent establishment in
India under Article 5 of the India-Qatar DTAA;
vi. On the facts and in the circumstances of the case
directing the AO to exclude the profits from
Oman Branch and Qatar Branch for tax purposes in India, holding
that as the assessee has been ... carrying on business through a
permanent establishment in Oman and Qatar and as the income from
the aforesaid branch in Oman and Qatar are derived
Rumana Abdul Kadar Khan, Doha, Qatar vs Income Tax Officer, Int. Tax. Ward - ... on 19 February, 2024
IN THE INCOME TAX APPELLATE TRIBUNAL ... wherein it was
submitted that
i. Assessee is working with the Qatar Airways and
used to visit India occasionally to meet her family.
A copy
