https://www.taxtmi.com/caselaws?id=333406 A non-resident was found to have a permanent establishment in India under the India-Swiss DTAA where client solicitation, bidding, contract execution and project closure were routed through a Chennai address, and the project coordinator acting as power of attorney holder was not shown to be an independent agent. The Tribunal also treated the Indian and foreign operations as intertwined, with functions going beyond preparatory or auxiliary activity. On computation, proportionate deduction for customs duty and other project-related expenses had to be allowed against the Indian rupee receipts, subject to section 43B of the Income-tax Act, and the Assessing Officer was directed to grant credit after verification. en-us Wed, 24 Aug 2016 00:00:00 +0530 Thu, 13 Oct 2016 09:42:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=333406 A non-resident was found to have a permanent establishment in India under the India-Swiss DTAA where client solicitation, bidding, contract execution and project closure were routed through a Chennai address, and the project coordinator acting as power of attorney holder was not shown to be an independent agent. The Tribunal also treated the Indian and foreign operations as intertwined, with functions going beyond preparatory or auxiliary activity. On computation, proportionate deduction for customs duty and other project-related expenses had to be allowed against the Indian rupee receipts, subject to section 43B of the Income-tax Act, and the Assessing Officer was directed to grant credit after verification. Case-Laws Income Tax Wed, 24 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=333406