https://www.taxtmi.com/caselaws?id=307052 On unchanged facts, the Tribunal followed the assessee's earlier years' ruling and upheld a fixed place permanent establishment in India, noting frequent employee visits, supervision over Indian operations, and a place of business at the subsidiary's disposal. It rejected the Revenue's case on a service permanent establishment and a dependent agent permanent establishment because no treaty conditions were shown: the subsidiary had no authority to conclude contracts and functioned independently. Telecom link charges were held not taxable as royalty, since they represented connectivity services without transfer of the right to use equipment or process. Profit attribution was remitted for fresh recomputation in line with the earlier methodology. en-us Fri, 27 Nov 2020 00:00:00 +0530 Wed, 15 Mar 2023 21:07:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307052 On unchanged facts, the Tribunal followed the assessee's earlier years' ruling and upheld a fixed place permanent establishment in India, noting frequent employee visits, supervision over Indian operations, and a place of business at the subsidiary's disposal. It rejected the Revenue's case on a service permanent establishment and a dependent agent permanent establishment because no treaty conditions were shown: the subsidiary had no authority to conclude contracts and functioned independently. Telecom link charges were held not taxable as royalty, since they represented connectivity services without transfer of the right to use equipment or process. Profit attribution was remitted for fresh recomputation in line with the earlier methodology. Case-Laws Income Tax Fri, 27 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307052