https://www.taxtmi.com/caselaws?id=302752 Distribution revenue received from an Indian distributor was treated, on the facts discussed, as not taxable as royalty and the distributor was not regarded as creating a permanent establishment in India; the treaty business-profits characterization was applied consistently with earlier years. Credit of tax deducted at source was to be verified and allowed where the corresponding revenue had been offered to tax in India. Credit was denied for revenue not chargeable to tax in India because the related income had not been returned, with the note that such credit could be claimed in the country where the income was taxed. en-us Wed, 08 Dec 2021 00:00:00 +0530 Wed, 15 Jun 2022 20:58:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302752 Distribution revenue received from an Indian distributor was treated, on the facts discussed, as not taxable as royalty and the distributor was not regarded as creating a permanent establishment in India; the treaty business-profits characterization was applied consistently with earlier years. Credit of tax deducted at source was to be verified and allowed where the corresponding revenue had been offered to tax in India. Credit was denied for revenue not chargeable to tax in India because the related income had not been returned, with the note that such credit could be claimed in the country where the income was taxed. Case-Laws Income Tax Wed, 08 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302752