https://www.taxtmi.com/caselaws?id=469881 The Tribunal's prior orders in the assessee's own case were followed on permanent establishment and business connection, and the Indian subsidiary was treated as a permanent establishment in India, with that issue decided against the assessee. Income attribution was governed by the settled computation basis applied earlier, and the reimbursement component was not deleted as a separate claim. Claims for full TDS credit and correct interest under section 244A required verification and were remanded to the Assessing Officer. The challenge to initiation of penalty proceedings under section 270A was held premature. en-us Tue, 31 Jan 2023 00:00:00 +0530 Wed, 08 Jul 2026 11:50:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469881 The Tribunal's prior orders in the assessee's own case were followed on permanent establishment and business connection, and the Indian subsidiary was treated as a permanent establishment in India, with that issue decided against the assessee. Income attribution was governed by the settled computation basis applied earlier, and the reimbursement component was not deleted as a separate claim. Claims for full TDS credit and correct interest under section 244A required verification and were remanded to the Assessing Officer. The challenge to initiation of penalty proceedings under section 270A was held premature. Case-Laws Income Tax Tue, 31 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469881