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The appellant is engaged in trading operations across ASEAN countries and also carries out sourcing and trading operations in respect of various products and equipments. In the year August, 1988, the assessee established a Liaison Office (‘LO’) in India [earlier known as Nissei Sangyo (Singapore) Pte Ltd.] for rendering preparatory and auxiliary services, including market research and liaison activities.

Shanti Prime Publication Pvt. Ltd.

Section 254(1) of the income tax Act, 1961 — Appeal — Powers of Tribunal — Tribunal cannot enhance an assessment in an appeal by the assessee — The powers of the Tribunal in disposing of an appeal are set in very wide terms, but, at same time, in the absence of a cross appeal or cross objection by the Department, the Tribunal cannot enhance an assessment in an appeal by the assessee. accordingly, the Tribunal is not competent to give a finding which is adverse to the assessee and make the latter's position worse than before — Hitachi High Technologies Singapore Pte ltd. vs. Deputy Commissioner of income tax [2019] 202 TTJ (Delhi) 273

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