https://www.taxtmi.com/caselaws?id=447436 ITAT Delhi held that income from software supply and automated services by foreign entity was not taxable in India. Following SC precedent in Morgan Stanley, no profit attribution was required when transactions were at arm's length between foreign party and Indian associated enterprise. PE determination became academic. Interest on tax refunds was directed to be taxed at 10% under India-Ireland DTAA. AO was directed to verify and grant TDS credit, and levy interest under section 234A as per statutory provisions for valid returns. en-us Fri, 22 Dec 2023 00:00:00 +0530 Mon, 25 Dec 2023 11:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447436 ITAT Delhi held that income from software supply and automated services by foreign entity was not taxable in India. Following SC precedent in Morgan Stanley, no profit attribution was required when transactions were at arm's length between foreign party and Indian associated enterprise. PE determination became academic. Interest on tax refunds was directed to be taxed at 10% under India-Ireland DTAA. AO was directed to verify and grant TDS credit, and levy interest under section 234A as per statutory provisions for valid returns. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447436