https://www.taxtmi.com/caselaws?id=427764 On unchanged facts, the Tribunal applied earlier binding rulings and the principle of consistency to hold that the assessee had a permanent establishment in India under the India-Spain DTAA, but rejected any higher profit attribution and deleted related expenditure disallowances. It also held that booking fee receipts and Altea system receipts were business income, not royalty, because the arrangement did not involve treaty royalty use of copyright, process or equipment. Interest under section 234B was deleted on the footing that tax was deductible at source, while TDS credit was remitted to the Assessing Officer for verification and grant in accordance with law. en-us Tue, 13 Sep 2022 00:00:00 +0530 Thu, 15 Sep 2022 17:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427764 On unchanged facts, the Tribunal applied earlier binding rulings and the principle of consistency to hold that the assessee had a permanent establishment in India under the India-Spain DTAA, but rejected any higher profit attribution and deleted related expenditure disallowances. It also held that booking fee receipts and Altea system receipts were business income, not royalty, because the arrangement did not involve treaty royalty use of copyright, process or equipment. Interest under section 234B was deleted on the footing that tax was deductible at source, while TDS credit was remitted to the Assessing Officer for verification and grant in accordance with law. Case-Laws Income Tax Tue, 13 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427764