https://www.taxtmi.com/caselaws?id=444915 Permanent establishment was not re-examined because the issue had attained finality from earlier appellate proceedings. Applying the principle of consistency, the Tribunal allowed deduction of distribution fee, development fee, marketing cost and central operating cost in computing attribution to the alleged PE. Booking fee under the CRS arrangement and receipts from the Altea system were held to be business income or service receipts, not royalty, as they did not involve use of a process, equipment or similar right in the required legal sense. Interest under section 234A was remanded for verification of the filing date, while interest under section 234B was deleted. en-us Mon, 16 Oct 2023 00:00:00 +0530 Wed, 25 Oct 2023 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444915 Permanent establishment was not re-examined because the issue had attained finality from earlier appellate proceedings. Applying the principle of consistency, the Tribunal allowed deduction of distribution fee, development fee, marketing cost and central operating cost in computing attribution to the alleged PE. Booking fee under the CRS arrangement and receipts from the Altea system were held to be business income or service receipts, not royalty, as they did not involve use of a process, equipment or similar right in the required legal sense. Interest under section 234A was remanded for verification of the filing date, while interest under section 234B was deleted. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444915