https://www.taxtmi.com/caselaws?id=361670 The majority held that a foreign enterprise's Indian subsidiary did not, on these facts, create a fixed place or dependent agent permanent establishment, and mere shareholding, control, shared offices, administrative support or expatriate presence was insufficient. For the offshore supply segment, no business connection was found and no further profit attribution was sustained for signing, network planning or negotiation activities in India, which were treated as preparatory or auxiliary. The majority also rejected tax on notional interest for delayed consideration, since no interest was charged, invoiced, accrued or received and no enforceable debt was shown. The dissent took a contrary view on PE, attribution and vendor financing interest. en-us Tue, 05 Jun 2018 00:00:00 +0530 Fri, 20 Jul 2018 15:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361670 The majority held that a foreign enterprise's Indian subsidiary did not, on these facts, create a fixed place or dependent agent permanent establishment, and mere shareholding, control, shared offices, administrative support or expatriate presence was insufficient. For the offshore supply segment, no business connection was found and no further profit attribution was sustained for signing, network planning or negotiation activities in India, which were treated as preparatory or auxiliary. The majority also rejected tax on notional interest for delayed consideration, since no interest was charged, invoiced, accrued or received and no enforceable debt was shown. The dissent took a contrary view on PE, attribution and vendor financing interest. Case-Laws Income Tax Tue, 05 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361670