https://www.taxtmi.com/caselaws?id=216999 Receipts from an online marketplace were treated as business profits, not fees for technical services, because the platform merely facilitated buyer-seller transactions and did not render managerial, technical or consultancy services to users. Indian entities providing market support, collection and administrative functions were found not to constitute a dependent agent permanent establishment or a place of management, as they did not habitually conclude contracts or exercise overall managerial control. In the absence of a treaty permanent establishment in India, the foreign enterprise's business profits from Indian operations were not taxable in India, and the addition was deleted. en-us Fri, 21 Sep 2012 00:00:00 +0530 Thu, 27 Sep 2012 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216999 Receipts from an online marketplace were treated as business profits, not fees for technical services, because the platform merely facilitated buyer-seller transactions and did not render managerial, technical or consultancy services to users. Indian entities providing market support, collection and administrative functions were found not to constitute a dependent agent permanent establishment or a place of management, as they did not habitually conclude contracts or exercise overall managerial control. In the absence of a treaty permanent establishment in India, the foreign enterprise's business profits from Indian operations were not taxable in India, and the addition was deleted. Case-Laws Income Tax Fri, 21 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216999