https://www.taxtmi.com/caselaws?id=774368 CRS booking fees and Altea system receipts were held not taxable as royalty under the Act or the treaty, following the assessee's earlier years' decisions and the jurisdictional High Court's consistent view that the CRS receipts were business income. The permanent establishment and attribution questions remained decided against the assessee, as prior appellate findings had already upheld the existence of a PE in India and the related profit attribution. Interest under section 234B was held not leviable because the relevant income was subject to tax deduction at source and no advance tax liability arose on the income assessed in India. en-us Fri, 04 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774368 CRS booking fees and Altea system receipts were held not taxable as royalty under the Act or the treaty, following the assessee's earlier years' decisions and the jurisdictional High Court's consistent view that the CRS receipts were business income. The permanent establishment and attribution questions remained decided against the assessee, as prior appellate findings had already upheld the existence of a PE in India and the related profit attribution. Interest under section 234B was held not leviable because the relevant income was subject to tax deduction at source and no advance tax liability arose on the income assessed in India. Case-Laws Income Tax Fri, 04 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774368