https://www.taxtmi.com/caselaws?id=306915 The Tribunal dismissed the appellant's challenge regarding the attribution of profits to the Permanent Establishment (PE) in India, citing the active involvement of Indian entity employees in securing orders for the appellant. The Tribunal upheld the previous decision regarding the taxation of software as royalty, following the precedent set by the ITAT and the Hon'ble Delhi High Court. The order was issued on 13th October 2022, applying uniformly to all appeals. en-us Thu, 13 Oct 2022 00:00:00 +0530 Sun, 05 Mar 2023 16:59:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306915 The Tribunal dismissed the appellant's challenge regarding the attribution of profits to the Permanent Establishment (PE) in India, citing the active involvement of Indian entity employees in securing orders for the appellant. The Tribunal upheld the previous decision regarding the taxation of software as royalty, following the precedent set by the ITAT and the Hon'ble Delhi High Court. The order was issued on 13th October 2022, applying uniformly to all appeals. Case-Laws Income Tax Thu, 13 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306915