https://www.taxtmi.com/caselaws?id=358523 An agency permanent establishment in India was held to exist on the basis of an earlier group decision, and the offshore supply of spare parts and offshore repair services was treated as taxable under the domestic law and treaty framework. For attribution of profits to Indian operations, the Tribunal rejected a 35% allocation and restricted the attributable income to 2.6% of sales made in India, following its earlier view in the group cases. Interest under section 234B was deleted because the jurisdictional High Court had already decided the issue against levy in the assessee's own case for earlier years. en-us Mon, 09 Apr 2018 00:00:00 +0530 Fri, 13 Apr 2018 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358523 An agency permanent establishment in India was held to exist on the basis of an earlier group decision, and the offshore supply of spare parts and offshore repair services was treated as taxable under the domestic law and treaty framework. For attribution of profits to Indian operations, the Tribunal rejected a 35% allocation and restricted the attributable income to 2.6% of sales made in India, following its earlier view in the group cases. Interest under section 234B was deleted because the jurisdictional High Court had already decided the issue against levy in the assessee's own case for earlier years. Case-Laws Income Tax Mon, 09 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358523