https://www.taxtmi.com/caselaws?id=63055 The notice under Section 142(1) was invalid due to time constraints, nullifying related assessments. Ericsson's appeal was allowed, with no PE or business connection in India, and software payments not deemed royalties. Motorola's appeal was partly allowed, recognizing a fixed place PE, with income attributed to it. Nokia's appeals were partly allowed, acknowledging PE through NTPL, attributing income to PE, and justifying notional interest addition, but software payments were not taxed as royalties. en-us Wed, 22 Jun 2005 00:00:00 +0530 Thu, 11 Jul 2024 13:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63055 The notice under Section 142(1) was invalid due to time constraints, nullifying related assessments. Ericsson's appeal was allowed, with no PE or business connection in India, and software payments not deemed royalties. Motorola's appeal was partly allowed, recognizing a fixed place PE, with income attributed to it. Nokia's appeals were partly allowed, acknowledging PE through NTPL, attributing income to PE, and justifying notional interest addition, but software payments were not taxed as royalties. Case-Laws Income Tax Wed, 22 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63055