https://www.taxtmi.com/caselaws?id=376441 The Tribunal partly allowed the appeal, directing the Assessing Officer to verify and correctly apply tax provisions. It emphasized determining the profit attributable to India and applying correct tax rates. The Tribunal held that income earned outside India is not taxable in India, overturning the Transfer Pricing Officer's adjustment and directing verification of actual profit attributable to India. The Tribunal also directed the correct application of tax rates on royalty income and granted TDS credit. Interest under Section 234C was not levied due to the non-resident status of the assessee. Penalty proceedings initiation was dismissed as premature. en-us Fri, 15 Feb 2019 00:00:00 +0530 Fri, 08 Mar 2019 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376441 The Tribunal partly allowed the appeal, directing the Assessing Officer to verify and correctly apply tax provisions. It emphasized determining the profit attributable to India and applying correct tax rates. The Tribunal held that income earned outside India is not taxable in India, overturning the Transfer Pricing Officer's adjustment and directing verification of actual profit attributable to India. The Tribunal also directed the correct application of tax rates on royalty income and granted TDS credit. Interest under Section 234C was not levied due to the non-resident status of the assessee. Penalty proceedings initiation was dismissed as premature. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376441