https://www.taxtmi.com/caselaws?id=421348 The article examines whether an assessee's project office and contract activities in India created a Permanent Establishment under the India-UAE DTAA, and whether related interest income could be taxed as PE income. It notes that earlier assessment findings relied on by the Assessing Officer had already been set aside by the Delhi High Court in the assessee's own case for prior years, where the absence of a PE meant no attribution of contract profits to India. The same approach was later followed by coordinate benches and the first appellate authority. On that basis, the assessee was treated as having no Permanent Establishment in India and the revenue's challenge to taxing the interest as PE income failed. en-us Wed, 06 Apr 2022 00:00:00 +0530 Thu, 21 Apr 2022 14:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421348 The article examines whether an assessee's project office and contract activities in India created a Permanent Establishment under the India-UAE DTAA, and whether related interest income could be taxed as PE income. It notes that earlier assessment findings relied on by the Assessing Officer had already been set aside by the Delhi High Court in the assessee's own case for prior years, where the absence of a PE meant no attribution of contract profits to India. The same approach was later followed by coordinate benches and the first appellate authority. On that basis, the assessee was treated as having no Permanent Establishment in India and the revenue's challenge to taxing the interest as PE income failed. Case-Laws Income Tax Wed, 06 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421348