https://www.taxtmi.com/caselaws?id=413952 The Tribunal allowed all appeals of the assessee and cross objections, dismissing the revenue's appeal. The Tribunal held that the Company had a Permanent Establishment (PE) in India, attributing 15% of gross revenue to India, resulting in no taxable income. Distribution expenses were allowed as deductions, with the Tribunal emphasizing their importance for CRS companies. Other expenses disallowed by the AO were directed to be re-computed at 30% in accordance with legal precedent, ultimately resulting in no taxable profit for the assessee. en-us Wed, 13 Oct 2021 00:00:00 +0530 Mon, 25 Oct 2021 16:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413952 The Tribunal allowed all appeals of the assessee and cross objections, dismissing the revenue's appeal. The Tribunal held that the Company had a Permanent Establishment (PE) in India, attributing 15% of gross revenue to India, resulting in no taxable income. Distribution expenses were allowed as deductions, with the Tribunal emphasizing their importance for CRS companies. Other expenses disallowed by the AO were directed to be re-computed at 30% in accordance with legal precedent, ultimately resulting in no taxable profit for the assessee. Case-Laws Income Tax Wed, 13 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413952