https://www.taxtmi.com/caselaws?id=392347 The Tribunal followed its earlier years' view that the non-resident assessee's activities in India were confined to services under the GRSE contract and did not constitute a permanent establishment under Article 5 of the India-UK DTAA; the related receipts were therefore not taxable in India on that basis. It also held that interest under sections 234B and 234C was not leviable on the non-resident assessee on the same facts. The disallowance concerning payments to Appledore International Ltd. under section 40(a)(ia) was treated as infructuous and did not survive as an independent issue. All Revenue appeals failed. en-us Wed, 12 Feb 2020 00:00:00 +0530 Tue, 18 Feb 2020 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392347 The Tribunal followed its earlier years' view that the non-resident assessee's activities in India were confined to services under the GRSE contract and did not constitute a permanent establishment under Article 5 of the India-UK DTAA; the related receipts were therefore not taxable in India on that basis. It also held that interest under sections 234B and 234C was not leviable on the non-resident assessee on the same facts. The disallowance concerning payments to Appledore International Ltd. under section 40(a)(ia) was treated as infructuous and did not survive as an independent issue. All Revenue appeals failed. Case-Laws Income Tax Wed, 12 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392347