https://www.taxtmi.com/caselaws?id=75829 A demarcated space in a customs bonded warehouse can constitute a fixed place permanent establishment when it has a distinct situs, sufficient permanence, and is operationally integrated with the non-resident enterprise's sales activities in India. Ownership and day-to-day operation by an independent service provider do not, by themselves, negate permanent establishment status where the space is allocated for the enterprise's goods, inventory control, security, and inspection rights. Once a permanent establishment exists, profits attributable to it must be computed on a separate and distinct enterprise basis under the treaty, with deductions allowed for payments to the warehouse or logistics provider and other relevant business expenses. en-us Thu, 25 Feb 2010 00:00:00 +0530 Thu, 31 Jan 2013 11:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75829 A demarcated space in a customs bonded warehouse can constitute a fixed place permanent establishment when it has a distinct situs, sufficient permanence, and is operationally integrated with the non-resident enterprise's sales activities in India. Ownership and day-to-day operation by an independent service provider do not, by themselves, negate permanent establishment status where the space is allocated for the enterprise's goods, inventory control, security, and inspection rights. Once a permanent establishment exists, profits attributable to it must be computed on a separate and distinct enterprise basis under the treaty, with deductions allowed for payments to the warehouse or logistics provider and other relevant business expenses. Case-Laws Income Tax Thu, 25 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75829