https://www.taxtmi.com/caselaws?id=259024 A foreign reinsurer's Indian subsidiary, acting as an independent contractor, did not create a business connection or a permanent establishment in India because the subsidiary was not shown to be an agent, broker, legal representative, service PE, or agency PE, and the treaty deeming rule for an insurance enterprise did not extend to reinsurance under the India-Switzerland DTAA. On that basis, the reinsurance income was not taxable in India. Interest under section 234B was also not sustained in the manner adopted in the assessment order, and the matter was resolved in favour of the assessee on both issues. en-us Fri, 13 Feb 2015 00:00:00 +0530 Mon, 06 Jul 2026 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259024 A foreign reinsurer's Indian subsidiary, acting as an independent contractor, did not create a business connection or a permanent establishment in India because the subsidiary was not shown to be an agent, broker, legal representative, service PE, or agency PE, and the treaty deeming rule for an insurance enterprise did not extend to reinsurance under the India-Switzerland DTAA. On that basis, the reinsurance income was not taxable in India. Interest under section 234B was also not sustained in the manner adopted in the assessment order, and the matter was resolved in favour of the assessee on both issues. Case-Laws Income Tax Fri, 13 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259024