https://www.taxtmi.com/caselaws?id=445753 The Tribunal held that the assessee did not have a fixed place permanent establishment in India through the project office at Vadodara or Bombardier Transportation India Limited, following its earlier decision on the same facts. As the permanent establishment test was not satisfied under the applicable treaty, the consequential attribution of profits and reclassification of interest income as business profits could not be sustained. The rectification and enhanced taxation based solely on the alleged permanent establishment were therefore deleted, and the assessee's appeals succeeded. en-us Wed, 15 Nov 2023 00:00:00 +0530 Sat, 18 Nov 2023 08:40:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445753 The Tribunal held that the assessee did not have a fixed place permanent establishment in India through the project office at Vadodara or Bombardier Transportation India Limited, following its earlier decision on the same facts. As the permanent establishment test was not satisfied under the applicable treaty, the consequential attribution of profits and reclassification of interest income as business profits could not be sustained. The rectification and enhanced taxation based solely on the alleged permanent establishment were therefore deleted, and the assessee's appeals succeeded. Case-Laws Income Tax Wed, 15 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445753