https://www.taxtmi.com/caselaws?id=359310 The Tribunal upheld the Assessing Officer's findings that the shipping company's place of effective management was in Gulf countries, not India or Mauritius, disqualifying it from DTAA benefits. It held that the agent in India was not a permanent establishment and business premises did not constitute a fixed place PE. The Tribunal dismissed penalty charges under Section 271(1)(c) due to debatable taxability issues. Consequently, all appeals by the assessee were allowed, and those by the revenue were dismissed. en-us Wed, 07 Mar 2018 00:00:00 +0530 Fri, 27 Apr 2018 08:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359310 The Tribunal upheld the Assessing Officer's findings that the shipping company's place of effective management was in Gulf countries, not India or Mauritius, disqualifying it from DTAA benefits. It held that the agent in India was not a permanent establishment and business premises did not constitute a fixed place PE. The Tribunal dismissed penalty charges under Section 271(1)(c) due to debatable taxability issues. Consequently, all appeals by the assessee were allowed, and those by the revenue were dismissed. Case-Laws Income Tax Wed, 07 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359310