https://www.taxtmi.com/caselaws?id=274645 Cross-border CRS operations were analysed on the basis of business connection and permanent establishment, with attribution determined by where core processing and database functions were performed. The limited role of equipment and connectivity in India, together with the functions-assets-risks test, showed that only a small part of the activity was carried on in India while the main operations and risks remained offshore. Income attribution was therefore required on a profits basis rather than by mechanically allocating gross receipts. On those facts, no income was chargeable to tax in India for the years considered. en-us Fri, 10 Jul 2009 00:00:00 +0530 Fri, 01 Mar 2024 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274645 Cross-border CRS operations were analysed on the basis of business connection and permanent establishment, with attribution determined by where core processing and database functions were performed. The limited role of equipment and connectivity in India, together with the functions-assets-risks test, showed that only a small part of the activity was carried on in India while the main operations and risks remained offshore. Income attribution was therefore required on a profits basis rather than by mechanically allocating gross receipts. On those facts, no income was chargeable to tax in India for the years considered. Case-Laws Income Tax Fri, 10 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274645