https://www.taxtmi.com/caselaws?id=258034 An earlier Tribunal finding that LTIL constituted only a service permanent establishment in India had attained finality, so the Revenue could not later recharacterise it as a fixed place, dependent agent, or installation permanent establishment. The Tribunal also upheld attribution of income at 2.5% of sales made by the overseas entities in India, holding that only profits attributable to activities carried on through the Indian permanent establishment may be taxed as business profits under the treaty, and that the CIT(A)'s basis was a reasonable measure in the absence of a better attribution method. The Revenue failed on both issues. 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 An earlier Tribunal finding that LTIL constituted only a service permanent establishment in India had attained finality, so the Revenue could not later recharacterise it as a fixed place, dependent agent, or installation permanent establishment. The Tribunal also upheld attribution of income at 2.5% of sales made by the overseas entities in India, holding that only profits attributable to activities carried on through the Indian permanent establishment may be taxed as business profits under the treaty, and that the CIT(A)'s basis was a reasonable measure in the absence of a better attribution method. The Revenue failed on both issues. Case-Laws Income Tax Fri, 04 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258034