https://www.taxtmi.com/caselaws?id=212933 The Tribunal partly allowed the appeal, determining that profits from cargo participation under "Slot Arrangement" were not entitled to benefits under Article 8 of the India-Germany DTAA. It was established that the assessee had an agency Permanent Establishment (PE) in India. The issue of interest levy under Section 234B was dismissed as consequential, and penalty proceedings initiation was deemed premature. The case was remanded to the Assessing Officer for assessing the profits attributable to the PE. en-us Wed, 07 Mar 2012 00:00:00 +0530 Sat, 16 Apr 2016 10:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212933 The Tribunal partly allowed the appeal, determining that profits from cargo participation under "Slot Arrangement" were not entitled to benefits under Article 8 of the India-Germany DTAA. It was established that the assessee had an agency Permanent Establishment (PE) in India. The issue of interest levy under Section 234B was dismissed as consequential, and penalty proceedings initiation was deemed premature. The case was remanded to the Assessing Officer for assessing the profits attributable to the PE. Case-Laws Income Tax Wed, 07 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212933