https://www.taxtmi.com/caselaws?id=237760 Receipts from marketing and management services performed outside India were treated as not attributable to a permanent establishment in India on factual findings, and the force of attraction theory was not accepted on the record. Reimbursement of lease line charges on a cost-to-cost basis was also found not to be royalty or income attributable to a permanent establishment, as no income element arose from that component. Interest under sections 234B and 234C was held inapplicable to a non-resident where the income was subject to tax deduction at source. The note also records that some questions were not entertained on merits. en-us Wed, 13 Feb 2013 00:00:00 +0530 Mon, 07 Oct 2013 21:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237760 Receipts from marketing and management services performed outside India were treated as not attributable to a permanent establishment in India on factual findings, and the force of attraction theory was not accepted on the record. Reimbursement of lease line charges on a cost-to-cost basis was also found not to be royalty or income attributable to a permanent establishment, as no income element arose from that component. Interest under sections 234B and 234C was held inapplicable to a non-resident where the income was subject to tax deduction at source. The note also records that some questions were not entertained on merits. Case-Laws Income Tax Wed, 13 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237760