https://www.taxtmi.com/caselaws?id=122389 Offshore sales of CKD units on a principal-to-principal basis, with delivery and payment completed outside India and no operations carried out in India for those transactions, did not create a business connection or fixed place/management PE; the related income was not taxable in India. Direct CBU sales through the Indian distributor also did not create a dependent agent PE because the distributor only acted as a communication channel, had no authority to conclude contracts, did not habitually secure orders, and performed only preparatory or auxiliary functions. In the absence of a PE and attributable profit-generating activity in India, no profits from the CBU sales were taxable in India. en-us Wed, 31 Mar 2010 00:00:00 +0530 Sat, 19 Aug 2023 10:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122389 Offshore sales of CKD units on a principal-to-principal basis, with delivery and payment completed outside India and no operations carried out in India for those transactions, did not create a business connection or fixed place/management PE; the related income was not taxable in India. Direct CBU sales through the Indian distributor also did not create a dependent agent PE because the distributor only acted as a communication channel, had no authority to conclude contracts, did not habitually secure orders, and performed only preparatory or auxiliary functions. In the absence of a PE and attributable profit-generating activity in India, no profits from the CBU sales were taxable in India. Case-Laws Income Tax Wed, 31 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122389