https://www.taxtmi.com/caselaws?id=296532 The assessee's Indian affiliate was treated as an independent contractor, and the facts did not satisfy Explanation 2 to section 9(1) for a business connection in India. The treaty conditions for a service permanent establishment or agency permanent establishment were also not met because the services were not shown to be rendered through the Indian entity as the assessee's employees or personnel. Following the assessee's earlier decision on substantially the same facts, the Tribunal held that no business connection or permanent establishment existed in India, so the income was not taxable in India on this issue. en-us Wed, 26 Dec 2018 00:00:00 +0530 Tue, 27 Jul 2021 08:53:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296532 The assessee's Indian affiliate was treated as an independent contractor, and the facts did not satisfy Explanation 2 to section 9(1) for a business connection in India. The treaty conditions for a service permanent establishment or agency permanent establishment were also not met because the services were not shown to be rendered through the Indian entity as the assessee's employees or personnel. Following the assessee's earlier decision on substantially the same facts, the Tribunal held that no business connection or permanent establishment existed in India, so the income was not taxable in India on this issue. Case-Laws Income Tax Wed, 26 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296532