https://www.taxtmi.com/caselaws?id=437420 Section 9(1)(i) read with Explanation 1(a) limits deemed Indian accrual to income reasonably attributable to operations carried out in India. The extent of attribution depends on a factual assessment of the business model, including functions performed, assets used and risks assumed. Applying a FAR analysis, the Tribunal attributed 15% of the foreign enterprise's revenue to Indian operations and treated the commission paid to Indian distribution agents as exceeding that attributed income, leaving no further taxable income in India. The High Court accepted that approach as reasonable, and no error justifying interference was shown. The attribution to Indian operations was therefore upheld and the Revenue's challenge failed. en-us Wed, 19 Apr 2023 00:00:00 +0530 Mon, 26 Jun 2023 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437420 Section 9(1)(i) read with Explanation 1(a) limits deemed Indian accrual to income reasonably attributable to operations carried out in India. The extent of attribution depends on a factual assessment of the business model, including functions performed, assets used and risks assumed. Applying a FAR analysis, the Tribunal attributed 15% of the foreign enterprise's revenue to Indian operations and treated the commission paid to Indian distribution agents as exceeding that attributed income, leaving no further taxable income in India. The High Court accepted that approach as reasonable, and no error justifying interference was shown. The attribution to Indian operations was therefore upheld and the Revenue's challenge failed. Case-Laws Income Tax Wed, 19 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437420