https://www.taxtmi.com/caselaws?id=409482 A project office used only as a communication channel and performing preparatory or auxiliary functions does not create a permanent establishment under the India-UAE DTAA. The installation and assembly project also failed the nine-month duration test, and the alleged dependent agent was treated as an independent agent that did not habitually conclude contracts on behalf of the assessee. On that basis, no permanent establishment existed in India, and once no permanent establishment was found, no income could be attributed to India. The Tribunal followed binding High Court precedent and did not depart from that view. en-us Thu, 01 Jul 2021 00:00:00 +0530 Fri, 09 Jul 2021 09:32:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409482 A project office used only as a communication channel and performing preparatory or auxiliary functions does not create a permanent establishment under the India-UAE DTAA. The installation and assembly project also failed the nine-month duration test, and the alleged dependent agent was treated as an independent agent that did not habitually conclude contracts on behalf of the assessee. On that basis, no permanent establishment existed in India, and once no permanent establishment was found, no income could be attributed to India. The Tribunal followed binding High Court precedent and did not depart from that view. Case-Laws Income Tax Thu, 01 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409482