https://www.taxtmi.com/caselaws?id=259733 Earlier-year precedent in the assessee's own case was followed on identical facts: services rendered in India through personnel were treated as giving rise to a service permanent establishment under the DTAA, and the PE was held to exist. The royalty and income-attribution questions were not finally decided on merits; they were remitted to the Assessing Officer for fresh computation in line with the prior year's directions and the applicable attribution mechanism. Interest under section 234B was held not leviable, while the remaining interest grounds under sections 234A, 234C and 234D were treated as consequential and did not survive independently. en-us Wed, 08 Apr 2015 00:00:00 +0530 Wed, 20 May 2015 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259733 Earlier-year precedent in the assessee's own case was followed on identical facts: services rendered in India through personnel were treated as giving rise to a service permanent establishment under the DTAA, and the PE was held to exist. The royalty and income-attribution questions were not finally decided on merits; they were remitted to the Assessing Officer for fresh computation in line with the prior year's directions and the applicable attribution mechanism. Interest under section 234B was held not leviable, while the remaining interest grounds under sections 234A, 234C and 234D were treated as consequential and did not survive independently. Case-Laws Income Tax Wed, 08 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259733