https://www.taxtmi.com/caselaws?id=6562 Under the India-Korea tax treaty, only business profits economically attributable to a permanent establishment in India are taxable in India, so profits from Korean designing and fabrication completed before the Indian permanent establishment existed were not taxable there. For the Indian installation, commissioning and hook-up operations, the rejected accounts justified best-judgment estimation, and the attributable profits were reasonably fixed at 10% of gross receipts. The treaty therefore protected the offshore profits, while the India-source operational income remained taxable on an estimated basis. en-us Fri, 18 May 2007 00:00:00 +0530 Mon, 15 Sep 2025 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6562 Under the India-Korea tax treaty, only business profits economically attributable to a permanent establishment in India are taxable in India, so profits from Korean designing and fabrication completed before the Indian permanent establishment existed were not taxable there. For the Indian installation, commissioning and hook-up operations, the rejected accounts justified best-judgment estimation, and the attributable profits were reasonably fixed at 10% of gross receipts. The treaty therefore protected the offshore profits, while the India-source operational income remained taxable on an estimated basis. Case-Laws Income Tax Fri, 18 May 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6562