https://www.taxtmi.com/caselaws?id=414050 A foreign enterprise carrying on advertisement-time business from Mauritius was analysed under the India-Mauritius DTAA on fixed place and dependent agent PE tests. The Tribunal stated that support services by the Indian entity and cross-transactions, without a fixed place in India at the foreign enterprise's disposal, did not by themselves establish a business connection or permanent establishment. It also applied the settled principle that where associated transactions are accepted at arm's length, no further profit attribution ordinarily survives, especially in the absence of a PE. The assessment additions on business connection, PE and profit attribution were therefore set aside. en-us Wed, 20 Oct 2021 00:00:00 +0530 Wed, 27 Oct 2021 09:21:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414050 A foreign enterprise carrying on advertisement-time business from Mauritius was analysed under the India-Mauritius DTAA on fixed place and dependent agent PE tests. The Tribunal stated that support services by the Indian entity and cross-transactions, without a fixed place in India at the foreign enterprise's disposal, did not by themselves establish a business connection or permanent establishment. It also applied the settled principle that where associated transactions are accepted at arm's length, no further profit attribution ordinarily survives, especially in the absence of a PE. The assessment additions on business connection, PE and profit attribution were therefore set aside. Case-Laws Income Tax Wed, 20 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414050