https://www.taxtmi.com/caselaws?id=412824 No permanent establishment existed in India under Article 5 of the India-US DTAA because the Indian agents were independent, acted in the ordinary course of their business, were not wholly or almost wholly devoted to the assessee, and had no authority to conclude contracts on its behalf. The software used by the agents also did not create a fixed place PE. As a result, no business profits were attributable to Indian operations under Article 7, and the corresponding tax addition was unsustainable. The ground relating to interest under section 234B did not survive independently. en-us Mon, 20 Sep 2021 00:00:00 +0530 Mon, 27 Sep 2021 08:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412824 No permanent establishment existed in India under Article 5 of the India-US DTAA because the Indian agents were independent, acted in the ordinary course of their business, were not wholly or almost wholly devoted to the assessee, and had no authority to conclude contracts on its behalf. The software used by the agents also did not create a fixed place PE. As a result, no business profits were attributable to Indian operations under Article 7, and the corresponding tax addition was unsustainable. The ground relating to interest under section 234B did not survive independently. Case-Laws Income Tax Mon, 20 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412824