https://www.taxtmi.com/caselaws?id=408106 Independent training centres were treated as third-party businesses, so the treaty conditions for denying independent status were not met and no dependent agent PE was fastened. Receipts from distance learning kits, DGR manuals and advertising space were characterised as outright sales or placement charges, because no right to use copyright, brand, goodwill or protected know-how was transferred; they were therefore not royalty. Receipts from BSP link charges, ICH facility and membership fees were said to depend on the role of the Indian branch and were remanded for factual verification. Claims for tax credit and interest under sections 234A, 234B and 234C were also restored for record verification, while penalty initiation was held premature. en-us Fri, 08 Jan 2021 00:00:00 +0530 Mon, 31 May 2021 13:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408106 Independent training centres were treated as third-party businesses, so the treaty conditions for denying independent status were not met and no dependent agent PE was fastened. Receipts from distance learning kits, DGR manuals and advertising space were characterised as outright sales or placement charges, because no right to use copyright, brand, goodwill or protected know-how was transferred; they were therefore not royalty. Receipts from BSP link charges, ICH facility and membership fees were said to depend on the role of the Indian branch and were remanded for factual verification. Claims for tax credit and interest under sections 234A, 234B and 234C were also restored for record verification, while penalty initiation was held premature. Case-Laws Income Tax Fri, 08 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408106