https://www.taxtmi.com/caselaws?id=185762 The Appellate Tribunal ITAT Mumbai upheld the CIT(A) decision in favor of the assessee regarding tax liability under the India-US DTAA for payments made by an Indian branch to a US-based entity. The Tribunal dismissed the Revenue's appeals, citing consistent precedent and lack of distinguishable features, ruling that the payments constituted 'business profits' under Article 7 and were not taxable in India due to the absence of a Permanent Establishment. en-us Thu, 10 Jun 2010 00:00:00 +0530 Fri, 26 Aug 2016 18:40:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185762 The Appellate Tribunal ITAT Mumbai upheld the CIT(A) decision in favor of the assessee regarding tax liability under the India-US DTAA for payments made by an Indian branch to a US-based entity. The Tribunal dismissed the Revenue's appeals, citing consistent precedent and lack of distinguishable features, ruling that the payments constituted 'business profits' under Article 7 and were not taxable in India due to the absence of a Permanent Establishment. Case-Laws Income Tax Thu, 10 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185762