https://www.taxtmi.com/caselaws?id=286239 A composite turnkey contract was treated as giving rise to a fixed place permanent establishment in India through the project office under the India-Korea DTAA, and the challenge to that finding failed. Profit attribution for offshore activities was not finally determined on the existing record and was restored for fresh factual examination with supporting attribution material. Disallowances linked to tax deduction at source issues and construction expenses were also sent back for verification because the recipient details, payment character, and supporting bills and vouchers required further scrutiny. The appeals therefore resulted in the permanent establishment finding being sustained, while the attribution and expenditure issues were remanded for fresh consideration. en-us Wed, 09 Jan 2019 00:00:00 +0530 Tue, 18 Feb 2020 08:28:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286239 A composite turnkey contract was treated as giving rise to a fixed place permanent establishment in India through the project office under the India-Korea DTAA, and the challenge to that finding failed. Profit attribution for offshore activities was not finally determined on the existing record and was restored for fresh factual examination with supporting attribution material. Disallowances linked to tax deduction at source issues and construction expenses were also sent back for verification because the recipient details, payment character, and supporting bills and vouchers required further scrutiny. The appeals therefore resulted in the permanent establishment finding being sustained, while the attribution and expenditure issues were remanded for fresh consideration. Case-Laws Income Tax Wed, 09 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286239