https://www.taxtmi.com/caselaws?id=122983 Where a non-resident enterprise's Indian agent or permanent establishment is remunerated at arm's length, Article 7 attribution leaves no further profits taxable in India. The Tribunal also noted that subscription revenue already assessed in the hands of the Indian entity could not be brought to tax again in the enterprise's hands, as the same receipt cannot be assessed twice and the related payment to the agent would be an allowable outgoing. On the non-resident's receipts, interest under section 234B was not chargeable because no underlying Indian tax liability survived. en-us Fri, 28 Jan 2011 00:00:00 +0530 Fri, 24 Aug 2012 12:14:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122983 Where a non-resident enterprise's Indian agent or permanent establishment is remunerated at arm's length, Article 7 attribution leaves no further profits taxable in India. The Tribunal also noted that subscription revenue already assessed in the hands of the Indian entity could not be brought to tax again in the enterprise's hands, as the same receipt cannot be assessed twice and the related payment to the agent would be an allowable outgoing. On the non-resident's receipts, interest under section 234B was not chargeable because no underlying Indian tax liability survived. Case-Laws Income Tax Fri, 28 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122983