https://www.taxtmi.com/caselaws?id=260840 Taxability of royalty and interest under the India-Korea treaty, attribution of spares and onshore GMR contract receipts to an Indian PE, and claims for service tax reimbursement and section 234B interest all required fresh factual verification. The Tribunal found that the record did not conclusively establish whether the Mumbai liaison office was an Indian PE for the HCEIPL arrangement, whether the GMR receipts were sufficiently linked to Indian operations, or whether the service tax and interest issues could be decided on the existing material. Each disputed issue was therefore remanded to the Assessing Officer for fresh adjudication, with no final determination on merits. en-us Fri, 05 Jun 2015 00:00:00 +0530 Thu, 25 Jun 2015 06:10:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260840 Taxability of royalty and interest under the India-Korea treaty, attribution of spares and onshore GMR contract receipts to an Indian PE, and claims for service tax reimbursement and section 234B interest all required fresh factual verification. The Tribunal found that the record did not conclusively establish whether the Mumbai liaison office was an Indian PE for the HCEIPL arrangement, whether the GMR receipts were sufficiently linked to Indian operations, or whether the service tax and interest issues could be decided on the existing material. Each disputed issue was therefore remanded to the Assessing Officer for fresh adjudication, with no final determination on merits. Case-Laws Income Tax Fri, 05 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260840