https://www.taxtmi.com/caselaws?id=234905 Receipts earned by the Indian branch from software product enhancement, customer care and medical transcription for the US head office were treated as taxable in India because the branch functioned as a permanent establishment under Article 7 of the Indo-US DTAA and the activities formed part of normal commercial operations. Article 7(3) was read as excluding only payments tied to specific non-commercial services for the head office, not income from ordinary business carried on by the permanent establishment, and the assessee failed to show that the work was non-commercial. Profit was required to be computed on the branch's own income, and in the absence of reliable computation data the 10% profit estimate was upheld. en-us Fri, 28 Jun 2013 00:00:00 +0530 Thu, 23 Apr 2015 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234905 Receipts earned by the Indian branch from software product enhancement, customer care and medical transcription for the US head office were treated as taxable in India because the branch functioned as a permanent establishment under Article 7 of the Indo-US DTAA and the activities formed part of normal commercial operations. Article 7(3) was read as excluding only payments tied to specific non-commercial services for the head office, not income from ordinary business carried on by the permanent establishment, and the assessee failed to show that the work was non-commercial. Profit was required to be computed on the branch's own income, and in the absence of reliable computation data the 10% profit estimate was upheld. Case-Laws Income Tax Fri, 28 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234905