https://www.taxtmi.com/caselaws?id=220497 Section 44BB deems 10% of qualifying receipts to be taxable profits, but a taxpayer seeking assessment on lower actual profit must maintain books of account and satisfy the audit requirements under sections 44AA(2) and 44AB. On the treaty issue, Article 7 of the DTAA was applied on the basis that a US enterprise is taxable in India only if it has a permanent establishment in India. The receipts were held not taxable in the absence of a permanent establishment, and the Revenue's appeals failed. en-us Mon, 26 Nov 2012 00:00:00 +0530 Mon, 02 Mar 2026 10:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220497 Section 44BB deems 10% of qualifying receipts to be taxable profits, but a taxpayer seeking assessment on lower actual profit must maintain books of account and satisfy the audit requirements under sections 44AA(2) and 44AB. On the treaty issue, Article 7 of the DTAA was applied on the basis that a US enterprise is taxable in India only if it has a permanent establishment in India. The receipts were held not taxable in the absence of a permanent establishment, and the Revenue's appeals failed. Case-Laws Income Tax Mon, 26 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220497