https://www.taxtmi.com/caselaws?id=418452 No permanent establishment arose in India where software installed at agents' premises did not itself create a taxable presence, the agents acted in the ordinary course of their business, their activities were not wholly or almost wholly devoted to the assessee, and the arrangements were on arm's length terms. The agents also lacked, and did not habitually exercise, authority to conclude contracts on the assessee's behalf, so they were not dependent agents. In the absence of a PE, profits could not be attributed to India under Article 7 of the India-USA DTAA, and the Revenue's grounds were rejected. en-us Mon, 14 Feb 2022 00:00:00 +0530 Thu, 17 Feb 2022 07:44:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418452 No permanent establishment arose in India where software installed at agents' premises did not itself create a taxable presence, the agents acted in the ordinary course of their business, their activities were not wholly or almost wholly devoted to the assessee, and the arrangements were on arm's length terms. The agents also lacked, and did not habitually exercise, authority to conclude contracts on the assessee's behalf, so they were not dependent agents. In the absence of a PE, profits could not be attributed to India under Article 7 of the India-USA DTAA, and the Revenue's grounds were rejected. Case-Laws Income Tax Mon, 14 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418452