https://www.taxtmi.com/caselaws?id=180459 A foreign enterprise's Indian subsidiary was treated as performing only preparatory or auxiliary functions for direct sales, with no authority to conclude contracts and no substantive canvassing or negotiation; the Tribunal therefore found no permanent establishment or business connection and no attribution of profits to India. Licence fees for Norton Antivirus software were also held not to be royalty because the transaction involved only use of a copyrighted article, with no transfer of copyright rights or right to commercially exploit the software. Interest under section 234B was treated as consequential and left to recomputation in line with the final tax position. en-us Tue, 30 Nov 2010 00:00:00 +0530 Fri, 25 Mar 2016 13:25:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180459 A foreign enterprise's Indian subsidiary was treated as performing only preparatory or auxiliary functions for direct sales, with no authority to conclude contracts and no substantive canvassing or negotiation; the Tribunal therefore found no permanent establishment or business connection and no attribution of profits to India. Licence fees for Norton Antivirus software were also held not to be royalty because the transaction involved only use of a copyrighted article, with no transfer of copyright rights or right to commercially exploit the software. Interest under section 234B was treated as consequential and left to recomputation in line with the final tax position. Case-Laws Income Tax Tue, 30 Nov 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180459