https://www.taxtmi.com/caselaws?id=280220 The commentary notes that, under the India-UK tax treaty, a permanent establishment in India may arise on the facts of the case, with tax confined to profits attributable to the Indian activities under Article 7. It also states that reimbursements of specific, actual expenses without any markup and supported by evidence are not treated as income. In addition, interest under section 234B is said to be unsustainable where binding precedent in the assessee's own case and the relevant jurisdictional ruling so require. The overall result described is a partial allowance of the assessee's appeals and rejection of the Revenue's appeals. en-us Wed, 16 Dec 2015 00:00:00 +0530 Fri, 26 Apr 2019 08:11:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280220 The commentary notes that, under the India-UK tax treaty, a permanent establishment in India may arise on the facts of the case, with tax confined to profits attributable to the Indian activities under Article 7. It also states that reimbursements of specific, actual expenses without any markup and supported by evidence are not treated as income. In addition, interest under section 234B is said to be unsustainable where binding precedent in the assessee's own case and the relevant jurisdictional ruling so require. The overall result described is a partial allowance of the assessee's appeals and rejection of the Revenue's appeals. Case-Laws Income Tax Wed, 16 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280220