https://www.taxtmi.com/caselaws?id=354307 Business income of a non-resident is taxable in India under Article 7 of the India-UAE DTAA only if a permanent establishment exists on the assessee's own facts. Reliance solely on an advance ruling concerning group concerns was insufficient to establish the assessee's PE. On the facts, the personnel were supplied on a principal-to-principal basis, no fixed place in India was shown to be at the assessee's disposal, the service activity did not exceed the treaty threshold under Article 5(2)(i), and the Indian entity was only a service recipient, not a dependent agent. The assessee therefore had no permanent establishment in India and the receipt was not taxable in India. en-us Fri, 19 Jan 2018 00:00:00 +0530 Thu, 21 May 2026 17:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354307 Business income of a non-resident is taxable in India under Article 7 of the India-UAE DTAA only if a permanent establishment exists on the assessee's own facts. Reliance solely on an advance ruling concerning group concerns was insufficient to establish the assessee's PE. On the facts, the personnel were supplied on a principal-to-principal basis, no fixed place in India was shown to be at the assessee's disposal, the service activity did not exceed the treaty threshold under Article 5(2)(i), and the Indian entity was only a service recipient, not a dependent agent. The assessee therefore had no permanent establishment in India and the receipt was not taxable in India. Case-Laws Income Tax Fri, 19 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354307