https://www.taxtmi.com/caselaws?id=413971 The article discusses attribution of income from Indian operations in a treaty and domestic tax context. It notes that the Tribunal treated business connection and permanent establishment in India as established, following earlier predecessor cases on the same factual matrix, and rejected the assessee's jurisdictional objection. It also applies the settled attribution approach that 15% of gross booking fees was attributable to India and, after allowing India-related expenses, no further taxable income survived. The practical effect was that Indian tax exposure was exhausted at the attribution stage even though the Indian presence objections failed. en-us Mon, 27 Sep 2021 00:00:00 +0530 Mon, 25 Oct 2021 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413971 The article discusses attribution of income from Indian operations in a treaty and domestic tax context. It notes that the Tribunal treated business connection and permanent establishment in India as established, following earlier predecessor cases on the same factual matrix, and rejected the assessee's jurisdictional objection. It also applies the settled attribution approach that 15% of gross booking fees was attributable to India and, after allowing India-related expenses, no further taxable income survived. The practical effect was that Indian tax exposure was exhausted at the attribution stage even though the Indian presence objections failed. Case-Laws Income Tax Mon, 27 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413971