2007 (5) TMI 196 - SC - Income Tax

Computation of the profits of the Indian (PE) of the Korean company - held that profits, if any, from the Korean operations (designing and fabrication) arose outside India, they are not taxable - As regards the quantum of profits embedded in the Indian operations attributable to the Indian PE, we hold that the CIT was right in attributing the profits to the Indian PE at 10 % of the gross receipts in respect of its activities of installation, commissioning etc. performed in India