https://www.taxtmi.com/caselaws?id=311681 A fixed place permanent establishment in India was found where the hotel premises were at the assessee's disposal and business was carried on through those premises, so the India-UAE Tax Treaty Article 5 test was satisfied and the PE finding was sustained. Profits attribution to that PE was not finally quantified in the present year; the matter was restored for fresh examination in line with the earlier appellate framework. The alternative taxation of receipts as royalty under the Income-tax Act and the Treaty was also sent back for fresh consideration rather than being determined on merits. en-us Tue, 27 Jul 2021 00:00:00 +0530 Mon, 08 Jan 2024 20:47:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311681 A fixed place permanent establishment in India was found where the hotel premises were at the assessee's disposal and business was carried on through those premises, so the India-UAE Tax Treaty Article 5 test was satisfied and the PE finding was sustained. Profits attribution to that PE was not finally quantified in the present year; the matter was restored for fresh examination in line with the earlier appellate framework. The alternative taxation of receipts as royalty under the Income-tax Act and the Treaty was also sent back for fresh consideration rather than being determined on merits. Case-Laws Income Tax Tue, 27 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311681