https://www.taxtmi.com/caselaws?id=450531 The ITAT Delhi ruled on a Spain-based assessee's tax liability in India. Following SC precedent, the assessee was deemed to have a fixed place PE under the India-Spain Tax Treaty. The HC determined 15% of revenue earned by appellant is taxable in India, directing AO to examine profits and tax accordingly. The Tribunal allowed deduction of distribution fees, development costs, and marketing expenses, following consistent treatment since 1996-97 and prior Tribunal orders for AY 2007-08 to 2020-21. Additions for CRS income-royalty and Altea system payments were deleted based on earlier Tribunal decisions. Interest under sections 234A and 234B was addressed per applicable circulars and precedent orders. 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 The ITAT Delhi ruled on a Spain-based assessee's tax liability in India. Following SC precedent, the assessee was deemed to have a fixed place PE under the India-Spain Tax Treaty. The HC determined 15% of revenue earned by appellant is taxable in India, directing AO to examine profits and tax accordingly. The Tribunal allowed deduction of distribution fees, development costs, and marketing expenses, following consistent treatment since 1996-97 and prior Tribunal orders for AY 2007-08 to 2020-21. Additions for CRS income-royalty and Altea system payments were deleted based on earlier Tribunal decisions. Interest under sections 234A and 234B was addressed per applicable circulars and precedent orders. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450531