https://www.taxtmi.com/caselaws?id=280219 Treaty-based permanent establishment was found in India because the assessee's services were rendered in India under Article 5(2)(k), and Article 15 did not alter that conclusion. Profit attribution to that permanent establishment had to be computed on actual revenues earned, so reworking client billing on a market-rate or arm's length basis was rejected. Reimbursements of actual expenses, supported by evidence and received without mark-up, were not taxable income. The assessee therefore succeeded only on the reimbursement issue, while the permanent establishment and attribution disputes were decided against it. en-us Wed, 07 May 2014 00:00:00 +0530 Fri, 26 Apr 2019 08:11:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280219 Treaty-based permanent establishment was found in India because the assessee's services were rendered in India under Article 5(2)(k), and Article 15 did not alter that conclusion. Profit attribution to that permanent establishment had to be computed on actual revenues earned, so reworking client billing on a market-rate or arm's length basis was rejected. Reimbursements of actual expenses, supported by evidence and received without mark-up, were not taxable income. The assessee therefore succeeded only on the reimbursement issue, while the permanent establishment and attribution disputes were decided against it. Case-Laws Income Tax Wed, 07 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280219