https://www.taxtmi.com/caselaws?id=393815 Continued foreign employment links and service deployment in India under a secondment arrangement can constitute a fixed place and service permanent establishment where the substance of the relationship shows employees rendering services in India for the associated enterprise. That finding was upheld against the assessee. Profit attribution, however, required fresh verification of the relocation expense base and global profitability material, so those computation issues were restored for reconsideration by the Assessing Officer. The rectification dispute and the grounds relating to penalty and interest were treated as infructuous, premature, or consequential and were not separately adjudicated. en-us Thu, 19 Mar 2020 00:00:00 +0530 Tue, 22 Sep 2020 16:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393815 Continued foreign employment links and service deployment in India under a secondment arrangement can constitute a fixed place and service permanent establishment where the substance of the relationship shows employees rendering services in India for the associated enterprise. That finding was upheld against the assessee. Profit attribution, however, required fresh verification of the relocation expense base and global profitability material, so those computation issues were restored for reconsideration by the Assessing Officer. The rectification dispute and the grounds relating to penalty and interest were treated as infructuous, premature, or consequential and were not separately adjudicated. Case-Laws Income Tax Thu, 19 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393815