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    <title>2016 (8) TMI 553 - ITAT CHENNAI</title>
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    <description>The Tribunal found that the assessee had a Permanent Establishment (PE) in India due to maintaining equipment in Chandigarh and Chennai, despite arguments to the contrary. The issue of attributing income to the PE was remitted for further examination. The classification of payments as &quot;Royalty&quot; or &quot;Fee for Technical Services&quot; was also remitted for re-evaluation. The Tribunal directed a reconsideration of the interest levy under section 234B and the deduction of tax at source rate. All issues were remitted back to the Assessing Officer for fresh examination, allowing appeals by both parties for statistical purposes.</description>
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      <description>The Tribunal found that the assessee had a Permanent Establishment (PE) in India due to maintaining equipment in Chandigarh and Chennai, despite arguments to the contrary. The issue of attributing income to the PE was remitted for further examination. The classification of payments as &quot;Royalty&quot; or &quot;Fee for Technical Services&quot; was also remitted for re-evaluation. The Tribunal directed a reconsideration of the interest levy under section 234B and the deduction of tax at source rate. All issues were remitted back to the Assessing Officer for fresh examination, allowing appeals by both parties for statistical purposes.</description>
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