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% 24.01.2011
Present: Mr. Ajay Vohra with Ms. Somnath Shukia and Mr. Somnath
Shukia, Advocates for the assessee.
Mr. Sanjeev Sabharwal, Sr. Standing Counsel for the
Revenue.
(COMMON ORDER)
+ITA Nos.191. 192. 193/2011
The only issue raised in these appeals which are filed by the same assessee but for the different assessment years is as to whether the assessee is running permanent establishment in India or not. We find that all the Authorities below, after taking into consideration various facts, have arrived at the finding of fact that the assessee is having permanent establishment in India. This being a finding offact, no question of law arises.
These appeals are accordingly dismissed.
CM Nos.1538. 1539. 1540. 1541. 1542/2011
In view of the aforesaid orders in appeals, ail the pending
CMS stand dismissed. A
K. SIKRI,J. M.L. MEHTA,J.
JANUARY 24, 2011 pmc i
2011:DHC:13555-DB
% 24.01.2011
Present: Mr. Ajay Vohra with Ms. Somnath Shukia and Mr. Somnath
Shukia, Advocates for the assessee.
Mr. Sanjeev Sabharwal, Sr. Standing Counsel for the
Revenue.
(COMMON ORDER)
+ITA Nos.191. 192. 193/2011
The only issue raised in these appeals which are filed by the same assessee but for the different assessment years is as to whether the assessee is running permanent establishment in India or not. We find that all the Authorities below, after taking into consideration various facts, have arrived at the finding of fact that the assessee is having permanent establishment in India. This being a finding offact, no question of law arises.
These appeals are accordingly dismissed.
CM Nos.1538. 1539. 1540. 1541. 1542/2011
In view of the aforesaid orders in appeals, ail the pending
CMS stand dismissed. A
K. SIKRI,J. M.L. MEHTA,J.
JANUARY 24, 2011 pmc i
2011:DHC:13555-DB
JUDGMENT