https://www.taxtmi.com/caselaws?id=357088 The tribunal partly allowed the appeals, directing the AO to follow the Mutual Agreement Procedure (MAP) settlement terms for determining the taxability of receipts. The tribunal held that certain charges were classified as Business Profits under the India-US Double Taxation Avoidance Treaty (DTAA) and were not taxable in India due to the absence of a Permanent Establishment (PE). The issue of reimbursement of expenses was remitted back to the AO for re-adjudication, and the initiation of penalty proceedings was dismissed as premature. en-us Wed, 14 Mar 2018 00:00:00 +0530 Sat, 17 Mar 2018 08:02:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357088 The tribunal partly allowed the appeals, directing the AO to follow the Mutual Agreement Procedure (MAP) settlement terms for determining the taxability of receipts. The tribunal held that certain charges were classified as Business Profits under the India-US Double Taxation Avoidance Treaty (DTAA) and were not taxable in India due to the absence of a Permanent Establishment (PE). The issue of reimbursement of expenses was remitted back to the AO for re-adjudication, and the initiation of penalty proceedings was dismissed as premature. Case-Laws Income Tax Wed, 14 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357088