https://www.taxtmi.com/caselaws?id=376542 Where the Indian subsidiary's remuneration was accepted at arm's length, no further profits could be attributed to the foreign enterprise on the basis of an alleged permanent establishment in India; the addition was deleted. On the levy of interest under section 234B, the document states that once the attribution addition failed, the basis for charging interest fell away, and that advance-tax interest was not exigible where the income was subject to tax deduction at source. The penalty ground was treated as premature and was not examined on merits. en-us Thu, 28 Feb 2019 00:00:00 +0530 Tue, 12 Mar 2019 08:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376542 Where the Indian subsidiary's remuneration was accepted at arm's length, no further profits could be attributed to the foreign enterprise on the basis of an alleged permanent establishment in India; the addition was deleted. On the levy of interest under section 234B, the document states that once the attribution addition failed, the basis for charging interest fell away, and that advance-tax interest was not exigible where the income was subject to tax deduction at source. The penalty ground was treated as premature and was not examined on merits. Case-Laws Income Tax Thu, 28 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376542