https://www.taxtmi.com/caselaws?id=286848 Cross-border sales completed on a principal-to-principal basis outside India did not create a fixed place or dependent agent permanent establishment, because the Indian distributor lacked authority to conclude contracts and acted as an independent distributor. On that footing, no business connection was found in India, and profits from offshore sales, accessories, promotional items and distribution fees were not attributable to India or taxable there merely because local distribution and support functions were performed in India. As the underlying income was held not taxable in India, interest under sections 234B and 234D did not survive as assessed and the assessment required consequential recomputation. en-us Mon, 16 Dec 2019 00:00:00 +0530 Wed, 18 Mar 2020 10:18:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286848 Cross-border sales completed on a principal-to-principal basis outside India did not create a fixed place or dependent agent permanent establishment, because the Indian distributor lacked authority to conclude contracts and acted as an independent distributor. On that footing, no business connection was found in India, and profits from offshore sales, accessories, promotional items and distribution fees were not attributable to India or taxable there merely because local distribution and support functions were performed in India. As the underlying income was held not taxable in India, interest under sections 234B and 234D did not survive as assessed and the assessment required consequential recomputation. Case-Laws Income Tax Mon, 16 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286848