https://www.taxtmi.com/caselaws?id=434819 The Tribunal considered whether the assessee had a fixed place, installation, service or dependent agent PE in India and whether offshore supply profits could be attributed to that PE, and it followed the consistent view taken in the assessee's earlier years, sustaining PE existence and attribution on the same factual matrix. It also held that the portion of receipts referable to software embedded in the equipment was not taxable as royalty, following the assessee's own precedent on identical facts. Alleged computational mistakes in the assessment were sent back to the Assessing Officer for verification after hearing the assessee. en-us Tue, 28 Feb 2023 00:00:00 +0530 Wed, 10 May 2023 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434819 The Tribunal considered whether the assessee had a fixed place, installation, service or dependent agent PE in India and whether offshore supply profits could be attributed to that PE, and it followed the consistent view taken in the assessee's earlier years, sustaining PE existence and attribution on the same factual matrix. It also held that the portion of receipts referable to software embedded in the equipment was not taxable as royalty, following the assessee's own precedent on identical facts. Alleged computational mistakes in the assessment were sent back to the Assessing Officer for verification after hearing the assessee. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434819