https://www.taxtmi.com/caselaws?id=208743 Remittances from integrated cargo transhipment operations were treated as arising from a business connection under section 9(1)(i) for source-based taxation, but treaty taxation under Article 7 depended on the Singapore enterprise carrying on business through a permanent establishment in India. The record did not show that the Indian company habitually concluded contracts, secured orders wholly or almost wholly for the non-resident, or otherwise constituted an agency permanent establishment under Article 5(8) or Article 5(9). The evidence was insufficient to establish the requisite treaty nexus, so the receipts could not be taxed in India merely on the basis of business connection once treaty protection applied. en-us Fri, 18 Nov 2011 00:00:00 +0530 Fri, 27 Jan 2012 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208743 Remittances from integrated cargo transhipment operations were treated as arising from a business connection under section 9(1)(i) for source-based taxation, but treaty taxation under Article 7 depended on the Singapore enterprise carrying on business through a permanent establishment in India. The record did not show that the Indian company habitually concluded contracts, secured orders wholly or almost wholly for the non-resident, or otherwise constituted an agency permanent establishment under Article 5(8) or Article 5(9). The evidence was insufficient to establish the requisite treaty nexus, so the receipts could not be taxed in India merely on the basis of business connection once treaty protection applied. Case-Laws Income Tax Fri, 18 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208743