https://www.taxtmi.com/caselaws?id=197114 The appeal was allowed in favor of the appellant on both grounds, with the Tribunal ruling that the appellant did not have a Permanent Establishment in India and that no income could be attributed to the alleged PE under the India-Germany Tax Treaty. The Tribunal emphasized the lack of a fixed place of business in India and the absence of an economic nexus with the alleged PE, leading to the decision that taxation should be at a lower rate of 10% on a gross basis under the Tax Treaty. en-us Wed, 06 Apr 2011 00:00:00 +0530 Wed, 27 Dec 2017 18:01:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=197114 The appeal was allowed in favor of the appellant on both grounds, with the Tribunal ruling that the appellant did not have a Permanent Establishment in India and that no income could be attributed to the alleged PE under the India-Germany Tax Treaty. The Tribunal emphasized the lack of a fixed place of business in India and the absence of an economic nexus with the alleged PE, leading to the decision that taxation should be at a lower rate of 10% on a gross basis under the Tax Treaty. Case-Laws Income Tax Wed, 06 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=197114