https://www.taxtmi.com/caselaws?id=280980 The HC did not decide the merits of the tax characterisation dispute or the treaty permanent establishment issue. It admitted the cross appeals and framed substantial questions of law on whether the receipts were business income or fees for technical services, including the applicable tax rate, and whether the assessee had a permanent establishment in India under the India-Singapore DTAA. The issue of interest under Sections 234B and 234C was noted as being covered against the Revenue by existing precedent, but no final adjudication was recorded and the matter was left open for final hearing if the position changed. en-us Thu, 22 Aug 2013 00:00:00 +0530 Wed, 29 May 2019 14:48:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280980 The HC did not decide the merits of the tax characterisation dispute or the treaty permanent establishment issue. It admitted the cross appeals and framed substantial questions of law on whether the receipts were business income or fees for technical services, including the applicable tax rate, and whether the assessee had a permanent establishment in India under the India-Singapore DTAA. The issue of interest under Sections 234B and 234C was noted as being covered against the Revenue by existing precedent, but no final adjudication was recorded and the matter was left open for final hearing if the position changed. Case-Laws Income Tax Thu, 22 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280980