https://www.taxtmi.com/caselaws?id=336646 The Tribunal allowed the assessee's appeals for the assessment years 2006-07, 2007-08, and 2008-09. It held that no further income was attributable to the assessee in India from the Permanent Establishment (PE) and that the payments made to non-residents did not constitute "royalty" under the Double Taxation Avoidance Agreement (DTAA). The disallowances under section 40(a)(i) were also deemed not sustainable. As a result, the Revenue's appeals were dismissed. en-us Fri, 23 Dec 2016 00:00:00 +0530 Mon, 26 Dec 2016 17:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336646 The Tribunal allowed the assessee's appeals for the assessment years 2006-07, 2007-08, and 2008-09. It held that no further income was attributable to the assessee in India from the Permanent Establishment (PE) and that the payments made to non-residents did not constitute "royalty" under the Double Taxation Avoidance Agreement (DTAA). The disallowances under section 40(a)(i) were also deemed not sustainable. As a result, the Revenue's appeals were dismissed. Case-Laws Income Tax Fri, 23 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336646