https://www.taxtmi.com/caselaws?id=63836 A non-resident's integrated reservation system, accessed through Indian connectivity, subscriber-side equipment and distributor-facilitated bookings, may create a business connection in India where the Indian activities form a real, intimate and continuous part of the revenue-generating process. On the treaty side, subscriber-side computers and Indian telecommunications infrastructure can constitute a fixed place PE, and a distributor authorised to enter subscriber contracts may amount to a dependent agent PE. Even where Indian tax nexus and PE exist, only profits attributable to Indian operations are taxable, and that attribution may be fully neutralised if remuneration paid to the Indian distributor exhausts the income attributable to the Indian PE. en-us Fri, 30 Nov 2007 00:00:00 +0530 Tue, 04 Jun 2024 12:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63836 A non-resident's integrated reservation system, accessed through Indian connectivity, subscriber-side equipment and distributor-facilitated bookings, may create a business connection in India where the Indian activities form a real, intimate and continuous part of the revenue-generating process. On the treaty side, subscriber-side computers and Indian telecommunications infrastructure can constitute a fixed place PE, and a distributor authorised to enter subscriber contracts may amount to a dependent agent PE. Even where Indian tax nexus and PE exist, only profits attributable to Indian operations are taxable, and that attribution may be fully neutralised if remuneration paid to the Indian distributor exhausts the income attributable to the Indian PE. Case-Laws Income Tax Fri, 30 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63836