https://www.taxtmi.com/caselaws?id=249223 The Tribunal held that the assessee had a service permanent establishment in India under Article 5(2)(k) of the Indo-UK DTAA because services were furnished through personnel in India for the requisite period. It further held that the royalty element was not wholly effectively connected with that permanent establishment, so the income issue was set aside and remanded to the Assessing Officer for recomputation in line with earlier directions. Interest under section 234B was not leviable because the relevant income had been disclosed in the return. The Revenue's cross objection on the treaty rate and Article 13(2) was held not maintainable, and the assessee was entitled to the 15% treaty rate. en-us Fri, 04 Jul 2014 00:00:00 +0530 Tue, 17 Mar 2015 12:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249223 The Tribunal held that the assessee had a service permanent establishment in India under Article 5(2)(k) of the Indo-UK DTAA because services were furnished through personnel in India for the requisite period. It further held that the royalty element was not wholly effectively connected with that permanent establishment, so the income issue was set aside and remanded to the Assessing Officer for recomputation in line with earlier directions. Interest under section 234B was not leviable because the relevant income had been disclosed in the return. The Revenue's cross objection on the treaty rate and Article 13(2) was held not maintainable, and the assessee was entitled to the 15% treaty rate. Case-Laws Income Tax Fri, 04 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249223