https://www.taxtmi.com/caselaws?id=310726 A foreign professional firm was held to have a permanent establishment in India under the India-UK DTAA, but only profits attributable to services performed in India were taxable there. Reimbursements of actual expenses incurred without markup were treated as non-income receipts and the disallowance was rejected. Interest under section 234B was held not leviable on the facts, following the assessee's own prior case law. The ruling therefore upheld treaty-based attribution for Indian taxation, excluded pure expense reimbursements from income, and deleted the interest charge. en-us Wed, 16 Dec 2015 00:00:00 +0530 Thu, 09 Nov 2023 20:50:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310726 A foreign professional firm was held to have a permanent establishment in India under the India-UK DTAA, but only profits attributable to services performed in India were taxable there. Reimbursements of actual expenses incurred without markup were treated as non-income receipts and the disallowance was rejected. Interest under section 234B was held not leviable on the facts, following the assessee's own prior case law. The ruling therefore upheld treaty-based attribution for Indian taxation, excluded pure expense reimbursements from income, and deleted the interest charge. Case-Laws Income Tax Wed, 16 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310726