https://www.taxtmi.com/caselaws?id=402058 Indian operations integral to negotiations, installation, supervision, and commissioning were treated as establishing business connection and multiple forms of permanent establishment in India, so offshore supply income including embedded software was assessed as business income attributable to the Indian presence, and not as isolated offshore sales or royalty. The Tribunal also held that, for a non-resident where tax was deductible at source, advance tax liability did not arise to that extent; consequently, interest under section 234B was not chargeable up to assessment year 2012-13 and was otherwise chargeable according to law thereafter. The additions were sustained, with limited relief only on interest for earlier years. en-us Wed, 09 Dec 2020 00:00:00 +0530 Mon, 18 Jan 2021 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402058 Indian operations integral to negotiations, installation, supervision, and commissioning were treated as establishing business connection and multiple forms of permanent establishment in India, so offshore supply income including embedded software was assessed as business income attributable to the Indian presence, and not as isolated offshore sales or royalty. The Tribunal also held that, for a non-resident where tax was deductible at source, advance tax liability did not arise to that extent; consequently, interest under section 234B was not chargeable up to assessment year 2012-13 and was otherwise chargeable according to law thereafter. The additions were sustained, with limited relief only on interest for earlier years. Case-Laws Income Tax Wed, 09 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402058