https://www.taxtmi.com/caselaws?id=234719 Territorial nexus confines taxation under section 9(1)(i) to income reasonably attributable to operations and services performed in India. The retrospective Finance Act 2010 amendment to the Explanation to section 9(1), being confined to clauses concerning specified categories of income, does not alter that position where income is assessed under section 9(1)(i). Under Article 7 of the India-UK DTAA, profits directly attributable to a permanent establishment are those it would earn as a distinct enterprise, while indirect attribution depends on its active contractual role and proportionate contribution. Services performed outside India cannot enter the Indian tax base merely because an Indian permanent establishment exists. en-us Mon, 13 May 2013 00:00:00 +0530 Mon, 20 Feb 2017 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234719 Territorial nexus confines taxation under section 9(1)(i) to income reasonably attributable to operations and services performed in India. The retrospective Finance Act 2010 amendment to the Explanation to section 9(1), being confined to clauses concerning specified categories of income, does not alter that position where income is assessed under section 9(1)(i). Under Article 7 of the India-UK DTAA, profits directly attributable to a permanent establishment are those it would earn as a distinct enterprise, while indirect attribution depends on its active contractual role and proportionate contribution. Services performed outside India cannot enter the Indian tax base merely because an Indian permanent establishment exists. Case-Laws Income Tax Mon, 13 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234719