https://www.taxtmi.com/caselaws?id=442203 Earlier coordinate bench rulings in the assessee's own case were followed on treaty PE and royalty questions. A fixed place PE in India was sustained because employees supervised and controlled Indian operations, a fixed place was at their disposal, and the business was projected through the Indian entity. A dependent agent PE and a service PE were rejected because the Indian entity lacked authority to conclude contracts or secure orders, and the treaty conditions for a service PE were not met. Link charges/IPLC charges were held not to be royalty, as no right to use equipment was transferred and the payments were treated as service procurement or reimbursement. Profit attribution to the PE was remitted for fresh computation on the earlier approved methodology. en-us Wed, 23 Aug 2023 00:00:00 +0530 Fri, 25 Aug 2023 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442203 Earlier coordinate bench rulings in the assessee's own case were followed on treaty PE and royalty questions. A fixed place PE in India was sustained because employees supervised and controlled Indian operations, a fixed place was at their disposal, and the business was projected through the Indian entity. A dependent agent PE and a service PE were rejected because the Indian entity lacked authority to conclude contracts or secure orders, and the treaty conditions for a service PE were not met. Link charges/IPLC charges were held not to be royalty, as no right to use equipment was transferred and the payments were treated as service procurement or reimbursement. Profit attribution to the PE was remitted for fresh computation on the earlier approved methodology. Case-Laws Income Tax Wed, 23 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442203