https://www.taxtmi.com/caselaws?id=378984 The tribunal ruled that the appellant's income was attributable to the Permanent Establishment in India and taxable as business profit, not royalty. It held that all payments received were attributable to the PE in India. The tribunal also confirmed that expenses for the PE had already been allowed under the India-Russia DTAA. However, the appellant was given a chance to provide necessary confirmations for transit office facility expenses. Additionally, the tribunal upheld the decision that interest under Section 234B was not chargeable, following relevant High Court judgments. The appeals of the assessee were partly allowed, while those of the revenue were dismissed. en-us Mon, 15 Apr 2019 00:00:00 +0530 Wed, 24 Apr 2019 12:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378984 The tribunal ruled that the appellant's income was attributable to the Permanent Establishment in India and taxable as business profit, not royalty. It held that all payments received were attributable to the PE in India. The tribunal also confirmed that expenses for the PE had already been allowed under the India-Russia DTAA. However, the appellant was given a chance to provide necessary confirmations for transit office facility expenses. Additionally, the tribunal upheld the decision that interest under Section 234B was not chargeable, following relevant High Court judgments. The appeals of the assessee were partly allowed, while those of the revenue were dismissed. Case-Laws Income Tax Mon, 15 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378984