https://www.taxtmi.com/caselaws?id=417912 Where an Indian subsidiary acts as a dependent agent on identical facts, the assessee is treated as having a business connection and permanent establishment in India. Income attribution is then limited by the earlier percentage-based approach: if commission and marketing fees paid to the Indian entity exceed the income attributable to Indian operations, no further addition is justified. Reimbursement of expenses is not separately taxable on the same facts when the attributed amount is already absorbed by amounts paid to the agent. Interest under section 244A must be recomputed up to the date the refund is actually granted. 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 Where an Indian subsidiary acts as a dependent agent on identical facts, the assessee is treated as having a business connection and permanent establishment in India. Income attribution is then limited by the earlier percentage-based approach: if commission and marketing fees paid to the Indian entity exceed the income attributable to Indian operations, no further addition is justified. Reimbursement of expenses is not separately taxable on the same facts when the attributed amount is already absorbed by amounts paid to the agent. Interest under section 244A must be recomputed up to the date the refund is actually granted. Case-Laws Income Tax Mon, 24 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417912