https://www.taxtmi.com/caselaws?id=306123 A non-resident was held to have no business connection or permanent establishment in India because it operated from outside India, had no office, fixed place of business, or employees in India, and the Indian entity acted as an independent principal-to-principal agent on arm's-length terms. As no income was attributable to India, estimation under Rule 10 could not be invoked. Section 40(a)(ia) was also held inapplicable because no taxable business income in India was established and no India-incurred deduction was claimed. Tax credit and related interest relief were allowed only to the extent of verification and consequential action by the Assessing Officer. en-us Wed, 08 Nov 2017 00:00:00 +0530 Tue, 18 Apr 2023 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306123 A non-resident was held to have no business connection or permanent establishment in India because it operated from outside India, had no office, fixed place of business, or employees in India, and the Indian entity acted as an independent principal-to-principal agent on arm's-length terms. As no income was attributable to India, estimation under Rule 10 could not be invoked. Section 40(a)(ia) was also held inapplicable because no taxable business income in India was established and no India-incurred deduction was claimed. Tax credit and related interest relief were allowed only to the extent of verification and consequential action by the Assessing Officer. Case-Laws Income Tax Wed, 08 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306123