https://www.taxtmi.com/caselaws?id=417912 The tribunal affirmed the existence of a permanent establishment (PE) in India for the appellant through its wholly-owned subsidiary, dismissing the challenge against it. Income attributable to the PE was calculated at 15% of gross receipts from India, resulting in no further tax charge due to marketing fees exceeding the calculated income. The tribunal allowed the appellant's appeal on reimbursement of expenses, directing no separate addition for it. TDS credit issue was dismissed due to lack of pressing by the appellant. The tribunal directed re-computation of interest under section 244A and dismissed issues related to interest under section 234B and premature penalty proceedings under section 270A. en-us Mon, 24 Jan 2022 00:00:00 +0530 Fri, 04 Feb 2022 07:01:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417912 The tribunal affirmed the existence of a permanent establishment (PE) in India for the appellant through its wholly-owned subsidiary, dismissing the challenge against it. Income attributable to the PE was calculated at 15% of gross receipts from India, resulting in no further tax charge due to marketing fees exceeding the calculated income. The tribunal allowed the appellant's appeal on reimbursement of expenses, directing no separate addition for it. TDS credit issue was dismissed due to lack of pressing by the appellant. The tribunal directed re-computation of interest under section 244A and dismissed issues related to interest under section 234B and premature penalty proceedings under section 270A. Case-Laws Income Tax Mon, 24 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417912