https://www.taxtmi.com/caselaws?id=450988 Under the India-Singapore DTAA, service permanent establishment requires actual furnishing of services in India through physical presence within the treaty threshold; as no fixed place or qualifying presence was shown, and the treaty did not recognise a virtual service permanent establishment, the receipts were not taxable in India as business profits. Interest under section 234B was not leviable because the relevant income was subject to deduction at source. Additions based only on Form 26AS entries for alleged bank receipts and refund interest could not be sustained without proof of actual receipt, so verification by the Assessing Officer was required before any fresh decision. en-us Thu, 14 Mar 2024 00:00:00 +0530 Wed, 14 Jan 2026 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450988 Under the India-Singapore DTAA, service permanent establishment requires actual furnishing of services in India through physical presence within the treaty threshold; as no fixed place or qualifying presence was shown, and the treaty did not recognise a virtual service permanent establishment, the receipts were not taxable in India as business profits. Interest under section 234B was not leviable because the relevant income was subject to deduction at source. Additions based only on Form 26AS entries for alleged bank receipts and refund interest could not be sustained without proof of actual receipt, so verification by the Assessing Officer was required before any fresh decision. Case-Laws Income Tax Thu, 14 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450988