https://www.taxtmi.com/caselaws?id=436213 The Tribunal ruled in favor of the assessee, determining that the subscription fees were classified as Business Profits and not subject to taxation in India due to the absence of a Permanent Establishment. The Tribunal rejected the classification of the fees as Fees for Technical Services or Fees for Included Services, emphasizing that the services provided did not involve technical knowledge transfer. As a result, penalty proceedings initiated under Section 270A were deemed unwarranted and dropped for both assessment years. en-us Wed, 05 Apr 2023 00:00:00 +0530 Fri, 07 Apr 2023 08:44:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436213 The Tribunal ruled in favor of the assessee, determining that the subscription fees were classified as Business Profits and not subject to taxation in India due to the absence of a Permanent Establishment. The Tribunal rejected the classification of the fees as Fees for Technical Services or Fees for Included Services, emphasizing that the services provided did not involve technical knowledge transfer. As a result, penalty proceedings initiated under Section 270A were deemed unwarranted and dropped for both assessment years. Case-Laws Income Tax Wed, 05 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436213