https://www.taxtmi.com/caselaws?id=289259 Profits of a foreign enterprise were taxable in India only to the extent attributable to the permanent establishment or business activities carried on in India under the treaty framework. Attribution required evidence that the receipts were generated through the Indian project office or otherwise linked to the assessee's Indian tax identity. In the absence of material supporting an arbitrary allocation, 25% of the gross receipts could not be brought to tax in India. The addition was therefore unsustainable and the issue was decided in favour of the assessee. en-us Fri, 27 Dec 2013 00:00:00 +0530 Thu, 23 Jul 2020 09:57:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289259 Profits of a foreign enterprise were taxable in India only to the extent attributable to the permanent establishment or business activities carried on in India under the treaty framework. Attribution required evidence that the receipts were generated through the Indian project office or otherwise linked to the assessee's Indian tax identity. In the absence of material supporting an arbitrary allocation, 25% of the gross receipts could not be brought to tax in India. The addition was therefore unsustainable and the issue was decided in favour of the assessee. Case-Laws Income Tax Fri, 27 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289259