https://www.taxtmi.com/caselaws?id=400451 Where the factual matrix is unchanged, binding jurisdictional precedent governs the tax treatment of a non-resident's Indian operations, including recognition of a fixed place and dependent agent permanent establishment and attribution of profits on the settled 15% basis. The commentary also notes that booking fee receipts under a computer reservation system were treated as business income rather than royalty, and that domestic law amendments cannot enlarge the treaty meaning of royalty absent treaty amendment. It further states that interest under section 234B is not leviable where tax was deductible at source, and TDS credit is to be allowed after verification. en-us Mon, 26 Oct 2020 00:00:00 +0530 Fri, 06 Nov 2020 18:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400451 Where the factual matrix is unchanged, binding jurisdictional precedent governs the tax treatment of a non-resident's Indian operations, including recognition of a fixed place and dependent agent permanent establishment and attribution of profits on the settled 15% basis. The commentary also notes that booking fee receipts under a computer reservation system were treated as business income rather than royalty, and that domestic law amendments cannot enlarge the treaty meaning of royalty absent treaty amendment. It further states that interest under section 234B is not leviable where tax was deductible at source, and TDS credit is to be allowed after verification. Case-Laws Income Tax Mon, 26 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400451