https://www.taxtmi.com/caselaws?id=380005 The Tribunal ruled in favor of the appellant, holding that the referral fees were not taxable in India as they did not accrue or arise in India and were not attributable to a Permanent Establishment in India. The Tribunal classified the referral fees as commission income, not Fees for Technical Services, following past judgments. Additionally, the interest paid by the Mumbai Branch to its Head Office was deemed not taxable in India, as per relevant case law. Penalty proceedings under section 271(1)(c) were likely impacted by the favorable decisions on primary grounds. The appeals for both Assessment Years were allowed in favor of the appellant. en-us Tue, 05 Mar 2019 00:00:00 +0530 Mon, 20 Jul 2026 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380005 The Tribunal ruled in favor of the appellant, holding that the referral fees were not taxable in India as they did not accrue or arise in India and were not attributable to a Permanent Establishment in India. The Tribunal classified the referral fees as commission income, not Fees for Technical Services, following past judgments. Additionally, the interest paid by the Mumbai Branch to its Head Office was deemed not taxable in India, as per relevant case law. Penalty proceedings under section 271(1)(c) were likely impacted by the favorable decisions on primary grounds. The appeals for both Assessment Years were allowed in favor of the appellant. Case-Laws Income Tax Tue, 05 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380005