https://www.taxtmi.com/caselaws?id=208106 Income attributable to Indian operations must be computed on a profits basis, limited to the portion of business activity reasonably connected with India. Where only a minor part of a non-resident's CRS activity was performed in India, the attributable profits were assessed by reference to functions performed, assets used and risks undertaken. The Tribunal's attribution of 15 per cent of booking revenue, yielding an amount lower than the Indian agent's allowable commission, meant that the attributed profits were fully absorbed by that commission. On that basis, no further income remained taxable in India beyond the amount already allowed as an expense. en-us Wed, 25 Feb 2009 00:00:00 +0530 Mon, 13 Jun 2016 11:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208106 Income attributable to Indian operations must be computed on a profits basis, limited to the portion of business activity reasonably connected with India. Where only a minor part of a non-resident's CRS activity was performed in India, the attributable profits were assessed by reference to functions performed, assets used and risks undertaken. The Tribunal's attribution of 15 per cent of booking revenue, yielding an amount lower than the Indian agent's allowable commission, meant that the attributed profits were fully absorbed by that commission. On that basis, no further income remained taxable in India beyond the amount already allowed as an expense. Case-Laws Income Tax Wed, 25 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208106