https://www.taxtmi.com/caselaws?id=431880 Referral fees earned by an overseas branch for introducing clients were treated as business income, not fees for technical services, because the activity was performed outside India and no nexus with the Indian permanent establishment was shown; the receipt was therefore not taxable in India on that basis. Interest paid between branches of the same legal entity was treated as a payment to self and did not give rise to taxable income in India. Section 115JB was held inapplicable to the foreign company on the facts, as MAT could not be used to tax amounts outside PE attribution or override the treaty framework governing branch profits. en-us Wed, 03 Aug 2022 00:00:00 +0530 Thu, 22 Dec 2022 11:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431880 Referral fees earned by an overseas branch for introducing clients were treated as business income, not fees for technical services, because the activity was performed outside India and no nexus with the Indian permanent establishment was shown; the receipt was therefore not taxable in India on that basis. Interest paid between branches of the same legal entity was treated as a payment to self and did not give rise to taxable income in India. Section 115JB was held inapplicable to the foreign company on the facts, as MAT could not be used to tax amounts outside PE attribution or override the treaty framework governing branch profits. Case-Laws Income Tax Wed, 03 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431880