https://www.taxtmi.com/caselaws?id=361380 ITAT Delhi held that supply income from telecommunication equipment was not attributable to a taxable permanent establishment in India, and activities in India did not justify taxing the assessee on that supply profit. It further held that receipts from embedded software supplied with the hardware were not separately taxable as royalty or business income because the software was part of the integrated supply transaction. The Tribunal also sustained proportionate research and development expenditure in the computation of the alleged Indian permanent establishment's income, finding no material to disallow it. The assessee therefore succeeded on the main taxability issues, with the Revenue failing on the deduction issue. en-us Mon, 28 May 2018 00:00:00 +0530 Wed, 06 Jun 2018 19:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361380 ITAT Delhi held that supply income from telecommunication equipment was not attributable to a taxable permanent establishment in India, and activities in India did not justify taxing the assessee on that supply profit. It further held that receipts from embedded software supplied with the hardware were not separately taxable as royalty or business income because the software was part of the integrated supply transaction. The Tribunal also sustained proportionate research and development expenditure in the computation of the alleged Indian permanent establishment's income, finding no material to disallow it. The assessee therefore succeeded on the main taxability issues, with the Revenue failing on the deduction issue. Case-Laws Income Tax Mon, 28 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361380