https://www.taxtmi.com/caselaws?id=214167 Offshore sale of CBU cars was treated as outside India where contracts were concluded on a principal-to-principal basis, with delivery and payment outside India, and no business connection or attributable permanent establishment in India was shown. An ad hoc software-rights royalty or fee addition was set aside for fresh factual verification because the assessee's evidence of no payment had not been examined. Interest under section 234B was held inapplicable to the non-resident extent covered by tax-deduction-at-source obligations. Penalty under section 271(1)(c) could not survive once the related quantum addition was deleted. en-us Wed, 07 Mar 2012 00:00:00 +0530 Tue, 19 Jun 2012 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214167 Offshore sale of CBU cars was treated as outside India where contracts were concluded on a principal-to-principal basis, with delivery and payment outside India, and no business connection or attributable permanent establishment in India was shown. An ad hoc software-rights royalty or fee addition was set aside for fresh factual verification because the assessee's evidence of no payment had not been examined. Interest under section 234B was held inapplicable to the non-resident extent covered by tax-deduction-at-source obligations. Penalty under section 271(1)(c) could not survive once the related quantum addition was deleted. Case-Laws Income Tax Wed, 07 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214167