https://www.taxtmi.com/caselaws?id=786227 Revenue attributable to an India permanent establishment was fixed at 15% under the cited Supreme Court precedent; the court concluded that this 15% represents revenue attributable to the PE, not a limit on deductible expenditure, and therefore the full distribution commission (68%) may be deducted against that attributed revenue, producing no taxable income. The question of taxability of transactions from non India points of sale remains undecided and is left to the appellate authorities. The impugned withholding order and certificate were set aside and a fresh tax withholding certificate at 0.5% was directed within fifteen days. en-us Wed, 28 Jan 2026 00:00:00 +0530 Mon, 09 Feb 2026 09:19:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786227 Revenue attributable to an India permanent establishment was fixed at 15% under the cited Supreme Court precedent; the court concluded that this 15% represents revenue attributable to the PE, not a limit on deductible expenditure, and therefore the full distribution commission (68%) may be deducted against that attributed revenue, producing no taxable income. The question of taxability of transactions from non India points of sale remains undecided and is left to the appellate authorities. The impugned withholding order and certificate were set aside and a fresh tax withholding certificate at 0.5% was directed within fifteen days. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786227