https://www.taxtmi.com/caselaws?id=389886 Service permanent establishment under the India-UK DTAA was treated as existing where employees were deputed and services continued in India for the required period, while royalty for transfer of intellectual property rights was held not to be effectively connected with that permanent establishment because the PE had no role in creating or exploiting those rights. Profit attribution to Indian operations was to be freshly determined on proper facts under Article 7 after hearing the assessee, and interest under sections 234A and 234B was left for verification based on the timing of return filing and the facts found. en-us Tue, 10 Dec 2019 00:00:00 +0530 Wed, 18 Dec 2019 15:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389886 Service permanent establishment under the India-UK DTAA was treated as existing where employees were deputed and services continued in India for the required period, while royalty for transfer of intellectual property rights was held not to be effectively connected with that permanent establishment because the PE had no role in creating or exploiting those rights. Profit attribution to Indian operations was to be freshly determined on proper facts under Article 7 after hearing the assessee, and interest under sections 234A and 234B was left for verification based on the timing of return filing and the facts found. Case-Laws Income Tax Tue, 10 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389886