ITAT couldn’t remand matter back to AO if it had all relevant doc. on record to conclude finding

Where there was all relevant documentary evidence available on record to render finding whether assessee a Netherland based company had a permanent establishment in India, Tribunal could not have remanded back matter to Assessing officer for fresh consideration especially when Assessing officer had not discharged burden of proving that assessee had a PE in India.

Refer:[2018] 97 taxmann.com 24 (Bombay)