https://www.taxtmi.com/caselaws?id=221788 A non-resident's Indian profit attribution must be made on a reasonable estimate where no separate books are maintained; applying Rule 10, the Tribunal accepted that 10% of advertising revenue was attributable to the Indian permanent establishment. It also followed binding jurisdictional authority that, where the income is subject to tax deduction at source, the non-resident has no advance tax obligation and interest under section 234B is not leviable, so the interest charge was deleted. The finding that the Indian agent's activities did not amount to a fixed place presence was also sustained. en-us Tue, 31 Jan 2012 00:00:00 +0530 Sat, 30 Mar 2013 08:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221788 A non-resident's Indian profit attribution must be made on a reasonable estimate where no separate books are maintained; applying Rule 10, the Tribunal accepted that 10% of advertising revenue was attributable to the Indian permanent establishment. It also followed binding jurisdictional authority that, where the income is subject to tax deduction at source, the non-resident has no advance tax obligation and interest under section 234B is not leviable, so the interest charge was deleted. The finding that the Indian agent's activities did not amount to a fixed place presence was also sustained. Case-Laws Income Tax Tue, 31 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221788