https://www.taxtmi.com/caselaws?id=435171 A treaty-linked arbitration settlement receipt was treated as taxable in India because it arose from project execution through the assessee's project office, establishing a real and not remote connection with the permanent establishment and bringing the amount within the provision on income effectively connected with that establishment. The claim for set-off of brought forward business losses was also accepted because the losses were substantiated on record, appellate directions required verification and allowance, and the omission to reflect the claim in the return did not justify denial of an otherwise legally allowable set-off. The settlement receipt remained taxable, while relief was granted on loss set-off. en-us Thu, 09 Mar 2023 00:00:00 +0530 Tue, 14 Mar 2023 08:59:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435171 A treaty-linked arbitration settlement receipt was treated as taxable in India because it arose from project execution through the assessee's project office, establishing a real and not remote connection with the permanent establishment and bringing the amount within the provision on income effectively connected with that establishment. The claim for set-off of brought forward business losses was also accepted because the losses were substantiated on record, appellate directions required verification and allowance, and the omission to reflect the claim in the return did not justify denial of an otherwise legally allowable set-off. The settlement receipt remained taxable, while relief was granted on loss set-off. Case-Laws Income Tax Thu, 09 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435171