https://www.taxtmi.com/caselaws?id=782044 Non-resident sales commission was found not taxable in India because the revenue failed to establish a business connection, fixed place permanent establishment, or any basis for attributing profits to India, and the relevant services were performed outside India. Royalty income could not be assessed as business income under section 44DA because no permanent establishment in India was proved and no effective connection between the rights or property and any such establishment was shown. Penalty proceedings under section 271AA for alleged non-reporting in Form No. 3CEB were also unsustainable where the disputed transactions did not give rise to taxable income in India. The Tribunal deleted the additions and penalty. en-us Fri, 21 Nov 2025 00:00:00 +0530 Mon, 24 Nov 2025 08:57:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782044 Non-resident sales commission was found not taxable in India because the revenue failed to establish a business connection, fixed place permanent establishment, or any basis for attributing profits to India, and the relevant services were performed outside India. Royalty income could not be assessed as business income under section 44DA because no permanent establishment in India was proved and no effective connection between the rights or property and any such establishment was shown. Penalty proceedings under section 271AA for alleged non-reporting in Form No. 3CEB were also unsustainable where the disputed transactions did not give rise to taxable income in India. The Tribunal deleted the additions and penalty. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782044