https://www.taxtmi.com/caselaws?id=243059 A dependent agent permanent establishment in India does not give rise to further profit attribution where the agent has already been remunerated at arm's length. On that basis, income from 21 voyages was treated as not taxable in the foreign enterprise's hands under the India-Singapore treaty. The commentary also notes that levy of interest under sections 234B and 234C did not survive, the point being covered against the revenue by binding jurisdictional precedent. en-us Wed, 24 Jul 2013 00:00:00 +0530 Sat, 25 Jan 2014 18:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243059 A dependent agent permanent establishment in India does not give rise to further profit attribution where the agent has already been remunerated at arm's length. On that basis, income from 21 voyages was treated as not taxable in the foreign enterprise's hands under the India-Singapore treaty. The commentary also notes that levy of interest under sections 234B and 234C did not survive, the point being covered against the revenue by binding jurisdictional precedent. Case-Laws Income Tax Wed, 24 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243059