https://www.taxtmi.com/caselaws?id=456269 An Indian distributor acting independently, in its own name and without authority to bind the foreign enterprise, does not constitute a dependent agent permanent establishment under the India-Ireland treaty. On that basis, payments to Google Ireland were not disallowable under section 40(a)(i), and the same receipts were also held not to be royalty or fees for technical services because no copyright or proprietary interest in the software platform was transferred and no managerial, technical or consultancy services were rendered. The books rejection was found unjustified for want of specific defects, while the CSR-linked 80G claim, MAT credit, TDS credit and refund computation were remitted for verification. en-us Mon, 31 Jul 2023 00:00:00 +0530 Thu, 11 Jul 2024 21:59:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456269 An Indian distributor acting independently, in its own name and without authority to bind the foreign enterprise, does not constitute a dependent agent permanent establishment under the India-Ireland treaty. On that basis, payments to Google Ireland were not disallowable under section 40(a)(i), and the same receipts were also held not to be royalty or fees for technical services because no copyright or proprietary interest in the software platform was transferred and no managerial, technical or consultancy services were rendered. The books rejection was found unjustified for want of specific defects, while the CSR-linked 80G claim, MAT credit, TDS credit and refund computation were remitted for verification. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456269