https://www.taxtmi.com/caselaws?id=418068 The Tribunal allowed the appeal of the US-based company, holding that it does not have a Permanent Establishment (PE) in India. Consequently, issues related to profit attribution, taxability of royalty, and interest were considered academic. The Tribunal directed the Assessing Officer to grant credit for Tax Deducted at Source and charge interest under Section 234C only on the returned income. en-us Mon, 17 Jan 2022 00:00:00 +0530 Tue, 08 Feb 2022 06:54:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418068 The Tribunal allowed the appeal of the US-based company, holding that it does not have a Permanent Establishment (PE) in India. Consequently, issues related to profit attribution, taxability of royalty, and interest were considered academic. The Tribunal directed the Assessing Officer to grant credit for Tax Deducted at Source and charge interest under Section 234C only on the returned income. Case-Laws Income Tax Mon, 17 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418068