https://www.taxtmi.com/caselaws?id=411408 Separate service order forms may be aggregated for the treaty service-PE duration test where the underlying Business Service Agreement operates as a single commercial arrangement and the activities are interrelated, sequential and commercially coherent. On those facts, the service permanent establishment in India was upheld because the work formed connected phases of one project rather than independent engagements. For profit attribution, receipts from services rendered outside India could not be fully assigned to the Indian PE; the computation had to be revisited on the basis of evidence relating to Indian and non-Indian services and expenses. The attribution issue was therefore remanded for fresh computation. en-us Thu, 12 Aug 2021 00:00:00 +0530 Wed, 25 Aug 2021 09:08:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411408 Separate service order forms may be aggregated for the treaty service-PE duration test where the underlying Business Service Agreement operates as a single commercial arrangement and the activities are interrelated, sequential and commercially coherent. On those facts, the service permanent establishment in India was upheld because the work formed connected phases of one project rather than independent engagements. For profit attribution, receipts from services rendered outside India could not be fully assigned to the Indian PE; the computation had to be revisited on the basis of evidence relating to Indian and non-Indian services and expenses. The attribution issue was therefore remanded for fresh computation. Case-Laws Income Tax Thu, 12 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411408