Linklaters v. ITO: Mumbai ITAT on Business Connection and PE

The decision of the Mumbai Bench of the Income Tax Appellate Tribunal in Linklaters LLP v. ITO is available (along with a summary) here. Besides reiterating that the retrospective amendments to Section 9 have nullified Ishikawajima and Clifford Chance (the same view was taken in Ashapur Minichem discussed here), the judgment by Hon’ble Pramod Kumar contains an elaborate discussion of several important questions of law in relation to international taxation, particularly on permanent establishment and attribution. Readers may refer to discussions on Legally India here and here. A fuller discussion on the judgment will follow subsequently.