https://www.taxtmi.com/caselaws?id=418943 A foreign enterprise is not treated as having a dependent agent permanent establishment where the local representative is an independent contractor, acts for other clients, lacks authority to conclude contracts, and only performs liaison and project-support functions. On those facts, the representative also cannot be characterised as an installation permanent establishment merely because of related contractual work by a consortium partner. In the absence of a permanent establishment, attribution of income in India fails, and receipts for engineering design and drawings supplied from abroad and paid outside India are not sustained on the tax treatment adopted by the Revenue. en-us Mon, 21 Feb 2022 00:00:00 +0530 Mon, 28 Feb 2022 08:33:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418943 A foreign enterprise is not treated as having a dependent agent permanent establishment where the local representative is an independent contractor, acts for other clients, lacks authority to conclude contracts, and only performs liaison and project-support functions. On those facts, the representative also cannot be characterised as an installation permanent establishment merely because of related contractual work by a consortium partner. In the absence of a permanent establishment, attribution of income in India fails, and receipts for engineering design and drawings supplied from abroad and paid outside India are not sustained on the tax treatment adopted by the Revenue. Case-Laws Income Tax Mon, 21 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418943