https://www.taxtmi.com/caselaws?id=469882 A foreign assessee had no fixed place or dependent agent PE in India where the Indian group entity acted as an independent principal-to-principal buyer, lacked authority to conclude contracts, and deliveries and transfer of property occurred outside India; its offshore sales and related receipts were therefore not taxable in India under the Act or treaty. Consequentially, interest under section 234B on the non-resident assessee could not stand on the assessment made and was to be recomputed in line with the reduced tax liability. The appeal was allowed and relief followed on both the principal taxability issue and the interest charge. en-us Mon, 16 Dec 2019 00:00:00 +0530 Wed, 08 Jul 2026 12:10:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469882 A foreign assessee had no fixed place or dependent agent PE in India where the Indian group entity acted as an independent principal-to-principal buyer, lacked authority to conclude contracts, and deliveries and transfer of property occurred outside India; its offshore sales and related receipts were therefore not taxable in India under the Act or treaty. Consequentially, interest under section 234B on the non-resident assessee could not stand on the assessment made and was to be recomputed in line with the reduced tax liability. The appeal was allowed and relief followed on both the principal taxability issue and the interest charge. Case-Laws Income Tax Mon, 16 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469882