https://www.taxtmi.com/caselaws?id=429607 A foreign reinsurer does not have a fixed place permanent establishment in India unless a place in India is at its disposal and business is carried on through that place; mere support functions by an Indian group entity are insufficient, and the core reinsurance activity remained outside India. An alleged dependent agent permanent establishment is tax-neutral where the Indian agent is already remunerated at arm's length, because no further profits survive for attribution. On that basis, the reinsurance receipts were not taxable in India as business profits. en-us Mon, 31 Oct 2022 00:00:00 +0530 Tue, 01 Nov 2022 11:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429607 A foreign reinsurer does not have a fixed place permanent establishment in India unless a place in India is at its disposal and business is carried on through that place; mere support functions by an Indian group entity are insufficient, and the core reinsurance activity remained outside India. An alleged dependent agent permanent establishment is tax-neutral where the Indian agent is already remunerated at arm's length, because no further profits survive for attribution. On that basis, the reinsurance receipts were not taxable in India as business profits. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429607