https://www.taxtmi.com/caselaws?id=293834 The Tribunal held that the income was chargeable to tax under section 5(2) of the Act as the assessee had a business connection in India. It was determined that 15% of the revenue accrued in India should be treated as income. The Tribunal found the assessee had a Permanent Establishment in India under DTAA, attributing 15% of revenue to India. The High Court upheld these findings. The Tribunal also addressed the deduction of expenditure, noting that no income would be chargeable in India due to excessive payments to another entity. The appeals were allowed, and penalties were deleted based on precedent. en-us Fri, 19 Jun 2009 00:00:00 +0530 Thu, 04 Mar 2021 14:47:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293834 The Tribunal held that the income was chargeable to tax under section 5(2) of the Act as the assessee had a business connection in India. It was determined that 15% of the revenue accrued in India should be treated as income. The Tribunal found the assessee had a Permanent Establishment in India under DTAA, attributing 15% of revenue to India. The High Court upheld these findings. The Tribunal also addressed the deduction of expenditure, noting that no income would be chargeable in India due to excessive payments to another entity. The appeals were allowed, and penalties were deleted based on precedent. Case-Laws Income Tax Fri, 19 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293834