https://www.taxtmi.com/caselaws?id=393356 Taj India was held not to be an agency permanent establishment of the foreign assessee under Article 5(4) of the India-Mauritius DTAA because the distributor acted independently on a principal-to-principal basis, with authority only to market and promote the channel and to enter arrangements in its own name. The Tribunal and first appellate authority found that Taj India did not habitually conclude contracts in the assessee's name and that the conditions for a dependent agent were absent. Those concurrent factual findings were not shown to be perverse, so no substantial question of law arose and the Revenue's challenge failed. en-us Thu, 06 Feb 2020 00:00:00 +0530 Wed, 19 Aug 2020 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393356 Taj India was held not to be an agency permanent establishment of the foreign assessee under Article 5(4) of the India-Mauritius DTAA because the distributor acted independently on a principal-to-principal basis, with authority only to market and promote the channel and to enter arrangements in its own name. The Tribunal and first appellate authority found that Taj India did not habitually conclude contracts in the assessee's name and that the conditions for a dependent agent were absent. Those concurrent factual findings were not shown to be perverse, so no substantial question of law arose and the Revenue's challenge failed. Case-Laws Income Tax Thu, 06 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393356