https://www.taxtmi.com/caselaws?id=237760 Receipts from marketing and management services performed outside India were treated as not attributable to an Indian permanent establishment on the recorded factual findings; the force-of-attraction theory was not specifically raised before lower authorities. Reimbursement of leased-line charges paid to an international telecom operator on a cost-to-cost basis did not generate income and was not treated as royalty or income attributable to a permanent establishment. For a non-resident whose income is subject to tax deduction at source, advance-tax interest under sections 234B and 234C does not arise. Findings of fact on permanent-establishment attribution and reimbursement receipts ordinarily do not warrant appellate interference. 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 an Indian permanent establishment on the recorded factual findings; the force-of-attraction theory was not specifically raised before lower authorities. Reimbursement of leased-line charges paid to an international telecom operator on a cost-to-cost basis did not generate income and was not treated as royalty or income attributable to a permanent establishment. For a non-resident whose income is subject to tax deduction at source, advance-tax interest under sections 234B and 234C does not arise. Findings of fact on permanent-establishment attribution and reimbursement receipts ordinarily do not warrant appellate interference. Case-Laws Income Tax Wed, 13 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237760