https://www.taxtmi.com/caselaws?id=244208 Foreign group entities were found to have a Permanent Establishment in India because the Indian premises were available for use, personnel were deputed, control over deployed staff remained with the foreign entities, and the group business operated in an integrated manner. As a result, the receipts from the Indian company were treated as business profits rather than standalone fees for technical services; where a treaty applied, taxation followed the business profits article, and where no treaty applied, the income was chargeable under the Act. Since the income was taxable in India, the Indian company was required to deduct tax at source under section 195. en-us Fri, 14 Feb 2014 00:00:00 +0530 Fri, 04 Apr 2014 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244208 Foreign group entities were found to have a Permanent Establishment in India because the Indian premises were available for use, personnel were deputed, control over deployed staff remained with the foreign entities, and the group business operated in an integrated manner. As a result, the receipts from the Indian company were treated as business profits rather than standalone fees for technical services; where a treaty applied, taxation followed the business profits article, and where no treaty applied, the income was chargeable under the Act. Since the income was taxable in India, the Indian company was required to deduct tax at source under section 195. Case-Laws Income Tax Fri, 14 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244208