https://www.taxtmi.com/caselaws?id=330445 The Tribunal set aside the assessment order and remanded the matter back to the AO for de-novo determination, considering the correct existing structure and agreements post-2007. The AO was directed to re-evaluate the Permanent Establishment (PE) status, classification of royalty income, restriction of expenses allowance, depreciation on trademarks, and levy of interest under sections 234D and 234B of the Income Tax Act. The appeal was allowed for statistical purposes, emphasizing the need for a thorough reconsideration of all issues based on the correct facts and applicable provisions. en-us Fri, 15 Jul 2016 00:00:00 +0530 Tue, 26 Jul 2016 11:50:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330445 The Tribunal set aside the assessment order and remanded the matter back to the AO for de-novo determination, considering the correct existing structure and agreements post-2007. The AO was directed to re-evaluate the Permanent Establishment (PE) status, classification of royalty income, restriction of expenses allowance, depreciation on trademarks, and levy of interest under sections 234D and 234B of the Income Tax Act. The appeal was allowed for statistical purposes, emphasizing the need for a thorough reconsideration of all issues based on the correct facts and applicable provisions. Case-Laws Income Tax Fri, 15 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330445