https://www.taxtmi.com/caselaws?id=296104 Profits are attributable to an Indian permanent establishment according to the extent of its revenue-generating operations in India, including marketing, contracting, banking, installation, support and after-sales activities; on that basis, attribution of 35% of net global profits was upheld. Software receipts supplied with hardware were treated as part of the business transaction and not as royalty merely because they were separately invoiced or described as licensed, so they were held not taxable as royalty. Interest under section 234B was directed to apply prospectively from assessment year 2013-14 in line with the amended provision. en-us Fri, 15 Feb 2019 00:00:00 +0530 Mon, 05 Jul 2021 08:24:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296104 Profits are attributable to an Indian permanent establishment according to the extent of its revenue-generating operations in India, including marketing, contracting, banking, installation, support and after-sales activities; on that basis, attribution of 35% of net global profits was upheld. Software receipts supplied with hardware were treated as part of the business transaction and not as royalty merely because they were separately invoiced or described as licensed, so they were held not taxable as royalty. Interest under section 234B was directed to apply prospectively from assessment year 2013-14 in line with the amended provision. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296104