https://www.taxtmi.com/caselaws?id=258034 The Tribunal upheld the classification of LTIL as a service Permanent Establishment (PE) of the assessee in India, with the Revenue's acceptance of this classification. The attribution of income to the Indian PE was based on the Revenue's previous profit attribution practices, leading to the dismissal of the appeal. The entire transaction of hardware and software supply was not solely attributed to the PE, as the sale of hardware was conducted without the involvement of a service PE. The appeal was ultimately dismissed, affirming LTIL's status as a service PE and the income attribution method. en-us Fri, 04 Jul 2014 00:00:00 +0530 Wed, 11 Mar 2015 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258034 The Tribunal upheld the classification of LTIL as a service Permanent Establishment (PE) of the assessee in India, with the Revenue's acceptance of this classification. The attribution of income to the Indian PE was based on the Revenue's previous profit attribution practices, leading to the dismissal of the appeal. The entire transaction of hardware and software supply was not solely attributed to the PE, as the sale of hardware was conducted without the involvement of a service PE. The appeal was ultimately dismissed, affirming LTIL's status as a service PE and the income attribution method. Case-Laws Income Tax Fri, 04 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258034