https://www.taxtmi.com/caselaws?id=343366 A permanent establishment in India under the India-US DTAA was upheld because earlier years' findings in the assessee's own case had already treated the Indian branch as a taxable presence, and the preparatory or auxiliary activity argument was rejected. Profit attribution to the Indian branch was not finally determined; following prior year directions, the matter was restored to the Assessing Officer for fresh recomputation in line with earlier appellate decisions. The appeal was therefore partly allowed, with the related revenue grounds disposed of for statistical purposes. en-us Fri, 05 May 2017 00:00:00 +0530 Wed, 24 May 2017 07:04:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343366 A permanent establishment in India under the India-US DTAA was upheld because earlier years' findings in the assessee's own case had already treated the Indian branch as a taxable presence, and the preparatory or auxiliary activity argument was rejected. Profit attribution to the Indian branch was not finally determined; following prior year directions, the matter was restored to the Assessing Officer for fresh recomputation in line with earlier appellate decisions. The appeal was therefore partly allowed, with the related revenue grounds disposed of for statistical purposes. Case-Laws Income Tax Fri, 05 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343366