https://www.taxtmi.com/caselaws?id=457629 A foreign assessee was held not to have a fixed place, service, or agency permanent establishment in India on materially identical facts and treaty language previously considered, so its business profits were not brought to tax in India and the attribution and gross profit grounds became academic. The Tribunal also restored the TDS credit claim for verification and recomputation, and remanded the section 234A interest issue because liability depended on factual verification of whether the return was filed within the due date. Interest under sections 234B and 234C was treated as consequential. en-us Mon, 03 May 2021 00:00:00 +0530 Tue, 24 Sep 2024 19:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457629 A foreign assessee was held not to have a fixed place, service, or agency permanent establishment in India on materially identical facts and treaty language previously considered, so its business profits were not brought to tax in India and the attribution and gross profit grounds became academic. The Tribunal also restored the TDS credit claim for verification and recomputation, and remanded the section 234A interest issue because liability depended on factual verification of whether the return was filed within the due date. Interest under sections 234B and 234C was treated as consequential. Case-Laws Income Tax Mon, 03 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457629