https://www.taxtmi.com/caselaws?id=59719 The Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decisions on all issues. It upheld that the Malaysian company did not have a PE in India, thus disallowing the deduction under Section 40(a)(i) of the IT Act was incorrect. The salary costs attributed to the Indian project were not head office expenses under Section 44C. Payments to ASC International, UK, were not taxable as the company lacked a PE in India. Payments to Dumul Technology Services B.V. were not taxable under Article 12 of the India-Netherlands treaty due to the absence of a PE. en-us Fri, 05 Dec 2008 00:00:00 +0530 Tue, 05 Dec 2023 14:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59719 The Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decisions on all issues. It upheld that the Malaysian company did not have a PE in India, thus disallowing the deduction under Section 40(a)(i) of the IT Act was incorrect. The salary costs attributed to the Indian project were not head office expenses under Section 44C. Payments to ASC International, UK, were not taxable as the company lacked a PE in India. Payments to Dumul Technology Services B.V. were not taxable under Article 12 of the India-Netherlands treaty due to the absence of a PE. Case-Laws Income Tax Fri, 05 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59719