https://www.taxtmi.com/caselaws?id=265024 Commission on local content or equipment reimbursement depends on the distribution and representation agreement: where the schedule excludes local non-Varian supplies from the commission base, the reimbursement issue requires fresh factual verification and the adjustment does not stand without proper examination. On permanent establishment, the Indian branch was held not to be a dependent agent PE of the foreign group entity under the applicable treaty position, following the assessee's earlier years' ruling; profit attribution in India was therefore deleted on the accepted facts. The interest ground did not survive for adjudication. en-us Fri, 28 Feb 2014 00:00:00 +0530 Tue, 06 Oct 2015 05:58:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265024 Commission on local content or equipment reimbursement depends on the distribution and representation agreement: where the schedule excludes local non-Varian supplies from the commission base, the reimbursement issue requires fresh factual verification and the adjustment does not stand without proper examination. On permanent establishment, the Indian branch was held not to be a dependent agent PE of the foreign group entity under the applicable treaty position, following the assessee's earlier years' ruling; profit attribution in India was therefore deleted on the accepted facts. The interest ground did not survive for adjudication. Case-Laws Income Tax Fri, 28 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265024