https://www.taxtmi.com/caselaws?id=450531 Binding precedent in the assessee's own case governed the fixed place permanent establishment, attribution, expenditure, royalty, and interest issues. The Tribunal upheld the existence of a fixed place permanent establishment under the India-Spain treaty, but required attribution of profits to be examined on the basis of the profit base and accounts, leading to relief in final computation. Following earlier years and co-ordinate bench orders, it deleted disallowance of distribution fee, development cost, marketing cost and central operating cost, and also deleted royalty additions on CRS and Altea receipts, holding the latter not taxable as royalty under the Act or treaty. Interest under sections 234A and 234B was also not sustained. en-us Tue, 05 Mar 2024 00:00:00 +0530 Wed, 06 Mar 2024 18:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450531 Binding precedent in the assessee's own case governed the fixed place permanent establishment, attribution, expenditure, royalty, and interest issues. The Tribunal upheld the existence of a fixed place permanent establishment under the India-Spain treaty, but required attribution of profits to be examined on the basis of the profit base and accounts, leading to relief in final computation. Following earlier years and co-ordinate bench orders, it deleted disallowance of distribution fee, development cost, marketing cost and central operating cost, and also deleted royalty additions on CRS and Altea receipts, holding the latter not taxable as royalty under the Act or treaty. Interest under sections 234A and 234B was also not sustained. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450531