https://www.taxtmi.com/caselaws?id=787425 The note addresses three tax issues: (i) royalty taxation - treaty and domestic tests require contractual entitlement or payment obligation for royalty; notional imputation to 100% was rejected and only the contractual receipts actually payable were treated as taxable, (ii) permanent establishment - treaty PE tests (fixed place/disposal, service PE duration threshold, dependent agent criteria) require factual proof; a local subsidiary remunerated at arm's length was not treated as a PE and no profits were attributable, and (iii) interest on underpayment of tax - advance tax computation must be recomputed with allowable reductions for deductible/collectible tax at source, remanded for recalculation. en-us Mon, 02 Mar 2026 00:00:00 +0530 Thu, 05 Mar 2026 08:41:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787425 The note addresses three tax issues: (i) royalty taxation - treaty and domestic tests require contractual entitlement or payment obligation for royalty; notional imputation to 100% was rejected and only the contractual receipts actually payable were treated as taxable, (ii) permanent establishment - treaty PE tests (fixed place/disposal, service PE duration threshold, dependent agent criteria) require factual proof; a local subsidiary remunerated at arm's length was not treated as a PE and no profits were attributable, and (iii) interest on underpayment of tax - advance tax computation must be recomputed with allowable reductions for deductible/collectible tax at source, remanded for recalculation. Case-Laws Income Tax Mon, 02 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787425