https://www.taxtmi.com/caselaws?id=431583 Article 7(1) of the India-Finland DTAA permits attribution to a permanent establishment only to the extent profits exist in the foreign enterprise. Where the Tribunal found that the enterprise had a global net loss, no profit could be notionally attributed to the alleged permanent establishment in India. On those facts, the questions on permanent establishment and profit attribution did not justify interference, and the issue was answered against the Revenue. en-us Fri, 02 Dec 2022 00:00:00 +0530 Mon, 14 Aug 2023 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431583 Article 7(1) of the India-Finland DTAA permits attribution to a permanent establishment only to the extent profits exist in the foreign enterprise. Where the Tribunal found that the enterprise had a global net loss, no profit could be notionally attributed to the alleged permanent establishment in India. On those facts, the questions on permanent establishment and profit attribution did not justify interference, and the issue was answered against the Revenue. Case-Laws Income Tax Fri, 02 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431583