https://www.taxtmi.com/caselaws?id=367225 Services rendered in India through deputed employees satisfied the treaty conditions for a service permanent establishment, so the existence of a service PE in India was upheld. Royalty received from India was not automatically effectively connected with that PE merely because the PE existed, and the issue of income attributable to Indian operations required fresh determination on the available material after reasonable opportunity of hearing. The tax credit and section 234A interest adjustments were treated as already rectified, while the challenge to initiation of penalty proceedings was premature and not entertained. en-us Tue, 11 Sep 2018 00:00:00 +0530 Mon, 17 Sep 2018 07:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=367225 Services rendered in India through deputed employees satisfied the treaty conditions for a service permanent establishment, so the existence of a service PE in India was upheld. Royalty received from India was not automatically effectively connected with that PE merely because the PE existed, and the issue of income attributable to Indian operations required fresh determination on the available material after reasonable opportunity of hearing. The tax credit and section 234A interest adjustments were treated as already rectified, while the challenge to initiation of penalty proceedings was premature and not entertained. Case-Laws Income Tax Tue, 11 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=367225