https://www.taxtmi.com/caselaws?id=282284 The judgment in this case involved 138 appeals related to assessment years 2001-02 to 2008-09. The reassessment challenge was found to be valid. It was established that permanent establishments existed in India for all overseas entities of the group. Income attribution was set at 2.6% of sales made in India. Interest under section 234B was deemed not chargeable. The lead case's decision was applied to all appeals, resulting in partial allowance based on reassessment validity, permanent establishment, income attribution, and interest chargeability. en-us Fri, 27 Jan 2017 00:00:00 +0530 Thu, 01 Aug 2019 05:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282284 The judgment in this case involved 138 appeals related to assessment years 2001-02 to 2008-09. The reassessment challenge was found to be valid. It was established that permanent establishments existed in India for all overseas entities of the group. Income attribution was set at 2.6% of sales made in India. Interest under section 234B was deemed not chargeable. The lead case's decision was applied to all appeals, resulting in partial allowance based on reassessment validity, permanent establishment, income attribution, and interest chargeability. Case-Laws Income Tax Fri, 27 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282284