https://www.taxtmi.com/caselaws?id=435325 Fixed place permanent establishment in India was upheld on the basis of the Indian subsidiary premises, the assessee's supervision and control, and the deployment of personnel and assets. Profits attributable to the alleged PE were not finally quantified and were remitted for recomputation in line with earlier binding directions. No dependent agent permanent establishment or service permanent establishment was found on the facts, and IPLC or link charges were held to be payment for services or reimbursement, not royalty taxable in India. The Revenue's appeal was dismissed and the assessee's appeal was partly allowed. en-us Mon, 06 Mar 2023 00:00:00 +0530 Thu, 16 Mar 2023 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435325 Fixed place permanent establishment in India was upheld on the basis of the Indian subsidiary premises, the assessee's supervision and control, and the deployment of personnel and assets. Profits attributable to the alleged PE were not finally quantified and were remitted for recomputation in line with earlier binding directions. No dependent agent permanent establishment or service permanent establishment was found on the facts, and IPLC or link charges were held to be payment for services or reimbursement, not royalty taxable in India. The Revenue's appeal was dismissed and the assessee's appeal was partly allowed. Case-Laws Income Tax Mon, 06 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435325