https://www.taxtmi.com/caselaws?id=432267 The Tribunal found that the non-resident corporate entity did not have a Dependent Agent Permanent Establishment (DAPE) in India through its Indian subsidiary, as the transactions were at arm's length. The attribution of business profits to the alleged DAPE was deemed unnecessary, and the computation of tax liability was impacted by this finding. The Tribunal directed the tax authority to allow credit for Taxes Deducted at Source (TDS) and ruled in favor of the assessee, concluding that the income from software supply was not taxable in India. en-us Fri, 21 Oct 2022 00:00:00 +0530 Mon, 02 Jan 2023 08:36:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432267 The Tribunal found that the non-resident corporate entity did not have a Dependent Agent Permanent Establishment (DAPE) in India through its Indian subsidiary, as the transactions were at arm's length. The attribution of business profits to the alleged DAPE was deemed unnecessary, and the computation of tax liability was impacted by this finding. The Tribunal directed the tax authority to allow credit for Taxes Deducted at Source (TDS) and ruled in favor of the assessee, concluding that the income from software supply was not taxable in India. Case-Laws Income Tax Fri, 21 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432267