https://www.taxtmi.com/caselaws?id=794654 Permanent establishment status was treated as settled against the assessee in India, following the earlier coordinate bench view. On attribution, the Tribunal held that income had to be computed on the settled basis and no further income could be taxed in India where marketing service fees paid to the Indian subsidiary exceeded the attributable income; this issue was decided for the assessee. A computation mismatch in the assessment order was sent back only for limited re-computation. Refund and interest claims under section 244A were left for consequential disposal, and initiation of penalty proceedings under section 270A was not interfered with as premature. en-us Fri, 29 May 2026 00:00:00 +0530 Thu, 09 Jul 2026 08:35:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794654 Permanent establishment status was treated as settled against the assessee in India, following the earlier coordinate bench view. On attribution, the Tribunal held that income had to be computed on the settled basis and no further income could be taxed in India where marketing service fees paid to the Indian subsidiary exceeded the attributable income; this issue was decided for the assessee. A computation mismatch in the assessment order was sent back only for limited re-computation. Refund and interest claims under section 244A were left for consequential disposal, and initiation of penalty proceedings under section 270A was not interfered with as premature. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794654