https://www.taxtmi.com/circulars?id=2856 Where an IT enabled entity in India performs incidental functions (procurement of orders, concluding contracts, call centre services) for a non resident principal, the insignificant profit attributable to those functions may be treated as part of the permanent establishment's income in India if charges are at arm's length; no separate income accrues to the non resident apart from the PE income. If the Indian entity performs core revenue generating activities, substantial profits attributable to those activities are taxable in India in accordance with the relevant tax treaty and domestic law. en-us Fri, 02 Jan 2004 00:00:00 +0530 Mon, 11 Aug 2008 11:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=2856 Where an IT enabled entity in India performs incidental functions (procurement of orders, concluding contracts, call centre services) for a non resident principal, the insignificant profit attributable to those functions may be treated as part of the permanent establishment's income in India if charges are at arm's length; no separate income accrues to the non resident apart from the PE income. If the Indian entity performs core revenue generating activities, substantial profits attributable to those activities are taxable in India in accordance with the relevant tax treaty and domestic law. Circulars Income Tax Fri, 02 Jan 2004 00:00:00 +0530 https://www.taxtmi.com/circulars?id=2856