https://www.taxtmi.com/caselaws?id=32791 The Authority determined that the receipts under the contract with Sterlite constituted 'royalty' income under the DTAA between India and Australia. It was held that the applicant did not have a Permanent Establishment in India. The Authority ruled that the entire receipts were taxable in India without applying the principle of apportionment, based on the significant activities conducted in India, rejecting the applicant's reliance on a previous court decision. en-us Mon, 30 Mar 2009 00:00:00 +0530 Wed, 20 May 2009 17:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32791 The Authority determined that the receipts under the contract with Sterlite constituted 'royalty' income under the DTAA between India and Australia. It was held that the applicant did not have a Permanent Establishment in India. The Authority ruled that the entire receipts were taxable in India without applying the principle of apportionment, based on the significant activities conducted in India, rejecting the applicant's reliance on a previous court decision. Case-Laws Income Tax Mon, 30 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32791