https://www.taxtmi.com/caselaws?id=308945 The delay in filing the appeal was condoned, and the appeals were accepted. The Tribunal attributed a percentage of the assessee's income to India based on revenue generated in India, resulting in different taxable income figures. The Tribunal's decision to follow the Galileo rule for income attribution was supported by referencing previous judgments. The Court emphasized the need for specific findings and considerations in determining taxable income and Permanent Establishment under the DTAA, directing the Tribunal to provide detailed findings after hearing both parties. en-us Tue, 20 Dec 2016 00:00:00 +0530 Wed, 02 Aug 2023 21:18:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308945 The delay in filing the appeal was condoned, and the appeals were accepted. The Tribunal attributed a percentage of the assessee's income to India based on revenue generated in India, resulting in different taxable income figures. The Tribunal's decision to follow the Galileo rule for income attribution was supported by referencing previous judgments. The Court emphasized the need for specific findings and considerations in determining taxable income and Permanent Establishment under the DTAA, directing the Tribunal to provide detailed findings after hearing both parties. Case-Laws Income Tax Tue, 20 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308945