https://www.taxtmi.com/caselaws?id=274790 Indian operations through the Indian subsidiary constituted a business connection and permanent establishment under the India-Singapore DTAA, and the earlier years' findings were followed because the facts remained unchanged. Income attributable to the Indian operations was confined to 15% of gross India bookings, and the commission paid to the Indian marketing company exceeded that attribution, leaving no further taxable income on that count. Receipts from the Indian subsidiary were not accepted as pure reimbursement; 10% was assessable as business income and available for set-off against commission. Treaty relief was denied on refund interest, foreign-currency loan benchmarking had to follow LIBOR plus 2%, and interest under section 234B was not leviable where tax was deductible at source. en-us Fri, 16 Feb 2018 00:00:00 +0530 Wed, 08 Jul 2026 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274790 Indian operations through the Indian subsidiary constituted a business connection and permanent establishment under the India-Singapore DTAA, and the earlier years' findings were followed because the facts remained unchanged. Income attributable to the Indian operations was confined to 15% of gross India bookings, and the commission paid to the Indian marketing company exceeded that attribution, leaving no further taxable income on that count. Receipts from the Indian subsidiary were not accepted as pure reimbursement; 10% was assessable as business income and available for set-off against commission. Treaty relief was denied on refund interest, foreign-currency loan benchmarking had to follow LIBOR plus 2%, and interest under section 234B was not leviable where tax was deductible at source. Case-Laws Income Tax Fri, 16 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274790