https://www.taxtmi.com/caselaws?id=394545 An Indian shipping agent was not treated as a dependent agent or agency permanent establishment where it acted as an independent agent in the ordinary course of business and not exclusively or almost exclusively for the foreign principals. On that basis, the foreign shipping companies were held to have no permanent establishment in India, so their shipping profits could not be taxed in India under the treaty framework. As a result, there was no basis to assess those receipts in the agent's hands as a representative assessee under section 44B, and the tax additions were deleted. en-us Fri, 31 Jan 2020 00:00:00 +0530 Thu, 16 Apr 2020 11:55:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394545 An Indian shipping agent was not treated as a dependent agent or agency permanent establishment where it acted as an independent agent in the ordinary course of business and not exclusively or almost exclusively for the foreign principals. On that basis, the foreign shipping companies were held to have no permanent establishment in India, so their shipping profits could not be taxed in India under the treaty framework. As a result, there was no basis to assess those receipts in the agent's hands as a representative assessee under section 44B, and the tax additions were deleted. Case-Laws Income Tax Fri, 31 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394545