https://www.taxtmi.com/caselaws?id=63842 A non-resident's India-facing booking and connectivity arrangement was treated as part of a real, intimate and continuous revenue-generating process, so business connection and deemed accrual of income in India were found. Applying the India-Spain DTAA, the Tribunal also treated configured subscriber computers and Indian operational control as a fixed place PE, and the economically dependent Indian marketing entity as an agency PE because it habitually concluded binding contracts and did more than preparatory or auxiliary work. However, only the Indian-attributable share of profits was relevant, and the remuneration paid to the Indian distributor fully absorbed that attribution, leaving no further taxable income and no surviving interest under sections 234A and 234B. en-us Fri, 30 Nov 2007 00:00:00 +0530 Tue, 30 Jan 2024 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63842 A non-resident's India-facing booking and connectivity arrangement was treated as part of a real, intimate and continuous revenue-generating process, so business connection and deemed accrual of income in India were found. Applying the India-Spain DTAA, the Tribunal also treated configured subscriber computers and Indian operational control as a fixed place PE, and the economically dependent Indian marketing entity as an agency PE because it habitually concluded binding contracts and did more than preparatory or auxiliary work. However, only the Indian-attributable share of profits was relevant, and the remuneration paid to the Indian distributor fully absorbed that attribution, leaving no further taxable income and no surviving interest under sections 234A and 234B. Case-Laws Income Tax Fri, 30 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63842