https://www.taxtmi.com/caselaws?id=239387 The Tribunal upheld that the Appellant had a Fixed Place Permanent Establishment (PE) in India and rejected the claim of merely procuring services. The Tribunal also determined the profits attributable to the PE based on transfer pricing principles. Regarding taxability, the Tribunal held that PeopleSoft license costs and maintenance charges were not taxable as "Royalty" but as reimbursement of expenses. Additionally, link charges were not considered taxable as "Equipment Royalty." The Tribunal upheld the levy of interest under certain sections and dismissed the revenue's appeal for one assessment year while partly allowing the assessee's appeals for two assessment years. en-us Fri, 10 May 2013 00:00:00 +0530 Fri, 17 Apr 2015 12:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239387 The Tribunal upheld that the Appellant had a Fixed Place Permanent Establishment (PE) in India and rejected the claim of merely procuring services. The Tribunal also determined the profits attributable to the PE based on transfer pricing principles. Regarding taxability, the Tribunal held that PeopleSoft license costs and maintenance charges were not taxable as "Royalty" but as reimbursement of expenses. Additionally, link charges were not considered taxable as "Equipment Royalty." The Tribunal upheld the levy of interest under certain sections and dismissed the revenue's appeal for one assessment year while partly allowing the assessee's appeals for two assessment years. Case-Laws Income Tax Fri, 10 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239387