https://www.taxtmi.com/caselaws?id=1852 Profits from foreign fabrication and delivery work completed in Korea were not taxable in India because they lacked the required economic nexus with the Indian permanent establishment under the treaty and the Income-tax Act; only profits attributable to the Indian permanent establishment could be taxed. By contrast, where the assessee's books were rejected and reliable supporting particulars were absent, the Court accepted a best-judgment estimate of profits from installation, commissioning and related Indian operations at 10% of gross receipts, consistent with the presumptive assessment approach applied to those receipts. en-us Fri, 18 May 2007 00:00:00 +0530 Sat, 02 Aug 2008 18:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=1852 Profits from foreign fabrication and delivery work completed in Korea were not taxable in India because they lacked the required economic nexus with the Indian permanent establishment under the treaty and the Income-tax Act; only profits attributable to the Indian permanent establishment could be taxed. By contrast, where the assessee's books were rejected and reliable supporting particulars were absent, the Court accepted a best-judgment estimate of profits from installation, commissioning and related Indian operations at 10% of gross receipts, consistent with the presumptive assessment approach applied to those receipts. Case-Laws Income Tax Fri, 18 May 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=1852