https://www.taxtmi.com/caselaws?id=213867 A foreign express-delivery enterprise operating through an Indian subsidiary may create a permanent establishment in India where the subsidiary performs the essential business functions of the India-linked operation under the India-Singapore tax treaty. On that footing, receipts from outbound and inbound consignments attributable to the Indian presence become taxable in India. The Authority also noted that any further attribution question depends on verification of whether the inter-company transactions were at arm's length. Because the income was treated as chargeable to tax in India, payments from the Indian counterparty were subject to withholding tax under section 195 of the Income-tax Act, 1961. en-us Thu, 07 Jun 2012 00:00:00 +0530 Wed, 12 Dec 2012 11:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213867 A foreign express-delivery enterprise operating through an Indian subsidiary may create a permanent establishment in India where the subsidiary performs the essential business functions of the India-linked operation under the India-Singapore tax treaty. On that footing, receipts from outbound and inbound consignments attributable to the Indian presence become taxable in India. The Authority also noted that any further attribution question depends on verification of whether the inter-company transactions were at arm's length. Because the income was treated as chargeable to tax in India, payments from the Indian counterparty were subject to withholding tax under section 195 of the Income-tax Act, 1961. Case-Laws Income Tax Thu, 07 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213867