https://www.taxtmi.com/caselaws?id=64866 Offshore supplies by a non-resident under contracts concluded in Italy on a principal-to-principal, arm's length basis were treated as not giving rise to income accruing or arising in India under section 9(1)(i), because there was no proof of over-invoicing, business operations in India, or profits earned there. Mere valuation acceptance by customs and a presumptive profit estimate were rejected as conjectural. Majority shareholding, common directors, and control of a subsidiary were also held insufficient to establish a business connection or permanent establishment under the Indo-Italian DTAA, since the subsidiary remained an independent entity and no agency, fixed place, or qualifying supervisory presence was proved. en-us Wed, 31 Oct 2007 00:00:00 +0530 Wed, 25 Jul 2012 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64866 Offshore supplies by a non-resident under contracts concluded in Italy on a principal-to-principal, arm's length basis were treated as not giving rise to income accruing or arising in India under section 9(1)(i), because there was no proof of over-invoicing, business operations in India, or profits earned there. Mere valuation acceptance by customs and a presumptive profit estimate were rejected as conjectural. Majority shareholding, common directors, and control of a subsidiary were also held insufficient to establish a business connection or permanent establishment under the Indo-Italian DTAA, since the subsidiary remained an independent entity and no agency, fixed place, or qualifying supervisory presence was proved. Case-Laws Income Tax Wed, 31 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64866