https://www.taxtmi.com/caselaws?id=65254 A non-resident money transfer business was held to have a business connection in India because the remittance process formed a seamless transaction completed only on delivery in India, supported by continuing arrangements with Indian agents and software-enabled verification. Taxability under domestic law was therefore upheld. However, no permanent establishment arose under Article 5 of the India-USA treaty: the Indian agents had no right to use premises as the assessee's own place of business, the liaison office performed only preparatory or auxiliary functions, the software was merely a verification tool, and the agents lacked authority to conclude contracts. In the absence of a PE, no profits were attributable to Indian operations under Article 7. en-us Fri, 10 Mar 2006 00:00:00 +0530 Sat, 23 Mar 2024 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65254 A non-resident money transfer business was held to have a business connection in India because the remittance process formed a seamless transaction completed only on delivery in India, supported by continuing arrangements with Indian agents and software-enabled verification. Taxability under domestic law was therefore upheld. However, no permanent establishment arose under Article 5 of the India-USA treaty: the Indian agents had no right to use premises as the assessee's own place of business, the liaison office performed only preparatory or auxiliary functions, the software was merely a verification tool, and the agents lacked authority to conclude contracts. In the absence of a PE, no profits were attributable to Indian operations under Article 7. Case-Laws Income Tax Fri, 10 Mar 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65254