Tribunal Rules No Business Connection in India; TDS Credit Granted, Penalty and Interest Dismissed.

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....Income accrued in India or not - Dependent Agent - PE in India or not? - The Tribunal upheld the assessee's argument that its operations did not constitute a business connection or PE in India, as core activities were conducted outside the country. Previous Tribunal decisions supported the conclusion that the Indian branch's activities were preparatory/auxiliary and did not constitute a PE. The Tribunal directed the assessing officer to allow TDS credit as claimed and dismissed penalty proceedings and interest levy.....