https://www.taxtmi.com/caselaws?id=383387 A non-resident CRS operator was found to have a permanent establishment in India through travel-agent connectivity, distribution arrangements and Indian support functions, including the Indian distributor structure. On attribution, only the profit reasonably connected with Indian operations was taxable because the core processing, database and mainframe functions were performed outside India; the Tribunal therefore restricted attribution to 15% of revenue from bookings made in India. Interest under section 234B was deleted because, where tax was deductible at source on payments to a non-resident, advance-tax default interest could not be levied on the payee. en-us Thu, 18 Jul 2019 00:00:00 +0530 Mon, 22 Jul 2019 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383387 A non-resident CRS operator was found to have a permanent establishment in India through travel-agent connectivity, distribution arrangements and Indian support functions, including the Indian distributor structure. On attribution, only the profit reasonably connected with Indian operations was taxable because the core processing, database and mainframe functions were performed outside India; the Tribunal therefore restricted attribution to 15% of revenue from bookings made in India. Interest under section 234B was deleted because, where tax was deductible at source on payments to a non-resident, advance-tax default interest could not be levied on the payee. Case-Laws Income Tax Thu, 18 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383387