https://www.taxtmi.com/caselaws?id=180587 Business connection and dependent agent permanent establishment in India were upheld on facts showing exclusive agency functions, contract negotiation, collection of revenue, common management and functional dependence. Where the Indian agent was remunerated at arm's length, no further profits were attributable to the permanent establishment in one appeal; in the connected appeal, attribution was remanded for fresh examination. Interest income on a simple loan was taxed at the treaty rate of 15% on gross basis as the treaty was more beneficial under section 90(2). Interest under section 234B was not sustained because the income was subject to tax deduction at source, leaving no advance tax liability. en-us Fri, 23 Jul 2010 00:00:00 +0530 Wed, 30 Mar 2016 10:52:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180587 Business connection and dependent agent permanent establishment in India were upheld on facts showing exclusive agency functions, contract negotiation, collection of revenue, common management and functional dependence. Where the Indian agent was remunerated at arm's length, no further profits were attributable to the permanent establishment in one appeal; in the connected appeal, attribution was remanded for fresh examination. Interest income on a simple loan was taxed at the treaty rate of 15% on gross basis as the treaty was more beneficial under section 90(2). Interest under section 234B was not sustained because the income was subject to tax deduction at source, leaving no advance tax liability. Case-Laws Income Tax Fri, 23 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180587