https://www.taxtmi.com/caselaws?id=327868 The Tribunal followed its earlier orders on identical facts and upheld the existence of a service permanent establishment in India under the treaty. It also held that the royalty component was not effectively connected with that permanent establishment, so income attribution had to be recomputed in line with the earlier year's treaty-based directions, and the matter was remanded to the Assessing Officer for fresh determination. On interest, section 234B was held not leviable on the Tribunal's earlier view, while the remaining interest provisions were treated as consequential. The appeal succeeded only in part. en-us Fri, 08 Apr 2016 00:00:00 +0530 Sat, 21 May 2016 12:39:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327868 The Tribunal followed its earlier orders on identical facts and upheld the existence of a service permanent establishment in India under the treaty. It also held that the royalty component was not effectively connected with that permanent establishment, so income attribution had to be recomputed in line with the earlier year's treaty-based directions, and the matter was remanded to the Assessing Officer for fresh determination. On interest, section 234B was held not leviable on the Tribunal's earlier view, while the remaining interest provisions were treated as consequential. The appeal succeeded only in part. Case-Laws Income Tax Fri, 08 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327868