https://www.taxtmi.com/caselaws?id=235843 Indian-source receipts were attributed at 15% of gross receipts from Indian operations, but the Tribunal held that marketing fees paid to the Indian subsidiary exhausted the attributable income, leaving no taxable surplus in India on that count. Treaty relief on refund interest failed because the assessee did not prove that the interest was remitted to or received in Singapore, and the reduced Article 11 rate could not be claimed on inference alone. A claimed reimbursement from the Indian affiliate was rejected as not established on the agreement or evidence, although no additional taxable income survived on the available attribution analysis. en-us Fri, 31 May 2013 00:00:00 +0530 Wed, 15 Apr 2015 18:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235843 Indian-source receipts were attributed at 15% of gross receipts from Indian operations, but the Tribunal held that marketing fees paid to the Indian subsidiary exhausted the attributable income, leaving no taxable surplus in India on that count. Treaty relief on refund interest failed because the assessee did not prove that the interest was remitted to or received in Singapore, and the reduced Article 11 rate could not be claimed on inference alone. A claimed reimbursement from the Indian affiliate was rejected as not established on the agreement or evidence, although no additional taxable income survived on the available attribution analysis. Case-Laws Income Tax Fri, 31 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235843