https://www.taxtmi.com/caselaws?id=415023 Re-domiciliation of a company from one offshore jurisdiction to Mauritius, by itself, did not justify denial of India-Mauritius treaty entitlement where fiscal domicile in Mauritius was not displaced and treaty benefit had been consistently accepted. On attribution of profits, where at most a dependent agent permanent establishment was alleged and the Indian agent had already been remunerated at arm's length for the functions and risks undertaken, no further profits survived for taxation in India. The dependent agent presence was therefore tax neutral, and the Revenue's grounds were rejected as infructuous. en-us Fri, 30 Jul 2021 00:00:00 +0530 Tue, 04 Aug 2026 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415023 Re-domiciliation of a company from one offshore jurisdiction to Mauritius, by itself, did not justify denial of India-Mauritius treaty entitlement where fiscal domicile in Mauritius was not displaced and treaty benefit had been consistently accepted. On attribution of profits, where at most a dependent agent permanent establishment was alleged and the Indian agent had already been remunerated at arm's length for the functions and risks undertaken, no further profits survived for taxation in India. The dependent agent presence was therefore tax neutral, and the Revenue's grounds were rejected as infructuous. Case-Laws Income Tax Fri, 30 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415023