https://www.taxtmi.com/caselaws?id=413562 Under Article 5 of the India-Mauritius DTAA, FCIPL was not established as a dependent agent permanent establishment because it did not work exclusively or almost exclusively for the assessee and carried on business for other principals as well. The facts also did not show that the assessee had any place in India at its disposal through FCIPL, so the requirements for a fixed place permanent establishment were not met. On that basis, the treaty did not permit Indian taxation of the assessee's shipping business profits on the Revenue's asserted PE footing. en-us Wed, 06 Oct 2021 00:00:00 +0530 Thu, 14 Oct 2021 09:15:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413562 Under Article 5 of the India-Mauritius DTAA, FCIPL was not established as a dependent agent permanent establishment because it did not work exclusively or almost exclusively for the assessee and carried on business for other principals as well. The facts also did not show that the assessee had any place in India at its disposal through FCIPL, so the requirements for a fixed place permanent establishment were not met. On that basis, the treaty did not permit Indian taxation of the assessee's shipping business profits on the Revenue's asserted PE footing. Case-Laws Income Tax Wed, 06 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413562