https://www.taxtmi.com/caselaws?id=782044 ITAT Delhi allowed the assessee's appeal. It held that sales commission received from the Indian group company for global sales support services was not taxable in India, as the agreements were finalized and services rendered outside India and no PE or business connection in India was established. Consequently, attribution of 35% of commission income to India was rejected. The Tribunal further held that royalty income could not be taxed as business income under section 44DA in absence of a PE, and directed deletion of related adjustments, noting tax was correctly deducted and offered under section 115A. Penalty under section 271AA for non-reporting of certain international transactions was also deleted. 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 ITAT Delhi allowed the assessee's appeal. It held that sales commission received from the Indian group company for global sales support services was not taxable in India, as the agreements were finalized and services rendered outside India and no PE or business connection in India was established. Consequently, attribution of 35% of commission income to India was rejected. The Tribunal further held that royalty income could not be taxed as business income under section 44DA in absence of a PE, and directed deletion of related adjustments, noting tax was correctly deducted and offered under section 115A. Penalty under section 271AA for non-reporting of certain international transactions was also deleted. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782044