Dismissing the appeal of the Revenue the Court held that the Tribunal had returned a finding of fact, that the assessee recorded a “global net loss” in the relevant assessment year, and therefore no profit could have possibly been attributed to it. Hence, there could be no assessment. Order of Tribunal is affirmed. (AY.2008-09 to 2011-12, 2013-14 to 2015-16)
CIT (IT) v. Nokia Solutions and Networks Oy (2023)455 ITR 157/147 taxmann.com 165 (Delhi)(HC)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent establishment-Global net loss-DTAA-India-Finland [Art. 7]