https://www.taxtmi.com/caselaws?id=264176 A foreign enterprise was held not to have a dependent agent permanent establishment in India because the Indian distributor did not habitually negotiate or conclude contracts, hold stock for regular delivery, or secure orders wholly or almost wholly for the enterprise, and its dealings were on a principal-to-principal basis. It also had no service permanent establishment because the Bureau Chief's India activities were limited to news gathering and reporting and were not services furnished for the distributor arrangement connected with the disputed receipts. On that basis, the distribution fee was not taxable in India under the treaty. en-us Fri, 28 Aug 2015 00:00:00 +0530 Sat, 19 Sep 2015 05:59:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264176 A foreign enterprise was held not to have a dependent agent permanent establishment in India because the Indian distributor did not habitually negotiate or conclude contracts, hold stock for regular delivery, or secure orders wholly or almost wholly for the enterprise, and its dealings were on a principal-to-principal basis. It also had no service permanent establishment because the Bureau Chief's India activities were limited to news gathering and reporting and were not services furnished for the distributor arrangement connected with the disputed receipts. On that basis, the distribution fee was not taxable in India under the treaty. Case-Laws Income Tax Fri, 28 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264176