https://www.taxtmi.com/caselaws?id=181428 A continuous and systematic role performed in India by a subsidiary in relation to a non-resident's tender-related and contract-signing activities can create a business connection under section 9(1)(i). The arrangement here went beyond isolated or preparatory functions because the subsidiary handled tender information, submission, follow-up, negotiation within set parameters, documentation, and contract execution on the applicant's behalf. On the assumed facts, those activities were sufficient to establish a permanent establishment under article 5 of the treaty, and the subsidiary's authority-and-contract functions meant articles 5.5 and 5.6 did not protect the applicant. en-us Tue, 27 Feb 1996 00:00:00 +0530 Sat, 16 Apr 2016 16:25:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181428 A continuous and systematic role performed in India by a subsidiary in relation to a non-resident's tender-related and contract-signing activities can create a business connection under section 9(1)(i). The arrangement here went beyond isolated or preparatory functions because the subsidiary handled tender information, submission, follow-up, negotiation within set parameters, documentation, and contract execution on the applicant's behalf. On the assumed facts, those activities were sufficient to establish a permanent establishment under article 5 of the treaty, and the subsidiary's authority-and-contract functions meant articles 5.5 and 5.6 did not protect the applicant. Case-Laws Income Tax Tue, 27 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181428