https://www.taxtmi.com/caselaws?id=296052 The court addressed the attribution of income to Permanent Establishment (PE) in India for offshore supplies, determining the rate of attribution, adjusting expenses for marketing services, and justifying a different rate for a specific assessment year. The judgment emphasized the significance of PE in taxation on offshore transactions, the complexity of calculating attribution rates, expense allocation, and adherence to international tax treaties. The court's analysis aimed to provide clarity on these international tax matters, ensuring a fair resolution in line with legal principles and international norms. en-us Fri, 18 Aug 2017 00:00:00 +0530 Fri, 02 Jul 2021 08:56:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296052 The court addressed the attribution of income to Permanent Establishment (PE) in India for offshore supplies, determining the rate of attribution, adjusting expenses for marketing services, and justifying a different rate for a specific assessment year. The judgment emphasized the significance of PE in taxation on offshore transactions, the complexity of calculating attribution rates, expense allocation, and adherence to international tax treaties. The court's analysis aimed to provide clarity on these international tax matters, ensuring a fair resolution in line with legal principles and international norms. Case-Laws Income Tax Fri, 18 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296052