https://www.taxtmi.com/caselaws?id=359485 Income of a non-resident can be attributed to a permanent establishment in India only where the Revenue proves, with evidence, that the income-generating operations were carried on through that establishment. The assessee showed that the Mumbai project office acted only as a communication channel and had no role in design, fabrication, procurement or offshore supply activities, while the Revenue failed to establish any nexus between those offshore receipts and the Indian office. On that factual and legal basis, attribution in India was not sustainable and the addition could not be upheld. en-us Wed, 25 Apr 2018 00:00:00 +0530 Tue, 01 May 2018 06:24:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359485 Income of a non-resident can be attributed to a permanent establishment in India only where the Revenue proves, with evidence, that the income-generating operations were carried on through that establishment. The assessee showed that the Mumbai project office acted only as a communication channel and had no role in design, fabrication, procurement or offshore supply activities, while the Revenue failed to establish any nexus between those offshore receipts and the Indian office. On that factual and legal basis, attribution in India was not sustainable and the addition could not be upheld. Case-Laws Income Tax Wed, 25 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359485