https://www.taxtmi.com/caselaws?id=328620 Profits attributable to a non-resident's Indian permanent establishment were to be determined on a reasonable basis reflecting the actual Indian functions performed, not by a fixed mechanical percentage; because no separate Indian books were maintained and significant marketing, negotiation, pricing, installation support and post-sale activities were carried out in India, Rule 10 applied and 35% of net global profits from India-related transactions was attributed to the PE. Receipts for software supplied as an integral part of telecom equipment were not royalty, since no copyright was transferred and the payment related to a copyrighted article, so the receipts were taxable as business income. Interest under section 234B was not leviable because tax was deductible at source by the payer under section 195. en-us Mon, 30 May 2016 00:00:00 +0530 Thu, 09 Jun 2016 19:18:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328620 Profits attributable to a non-resident's Indian permanent establishment were to be determined on a reasonable basis reflecting the actual Indian functions performed, not by a fixed mechanical percentage; because no separate Indian books were maintained and significant marketing, negotiation, pricing, installation support and post-sale activities were carried out in India, Rule 10 applied and 35% of net global profits from India-related transactions was attributed to the PE. Receipts for software supplied as an integral part of telecom equipment were not royalty, since no copyright was transferred and the payment related to a copyrighted article, so the receipts were taxable as business income. Interest under section 234B was not leviable because tax was deductible at source by the payer under section 195. Case-Laws Income Tax Mon, 30 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328620