https://www.taxtmi.com/caselaws?id=429607 The Tribunal held that the appellant did not have a fixed place Permanent Establishment (PE) in India and that the core reinsurance activity was conducted outside India. The services provided by RGA Services were deemed to be at arm's length, leading to no further profit attribution. The existence of a Dependent Agent PE was considered irrelevant due to the arm's length remuneration. As a result, the business profits from reinsurance activities had no tax implications in India, and the appeal was allowed in favor of the appellant. 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 The Tribunal held that the appellant did not have a fixed place Permanent Establishment (PE) in India and that the core reinsurance activity was conducted outside India. The services provided by RGA Services were deemed to be at arm's length, leading to no further profit attribution. The existence of a Dependent Agent PE was considered irrelevant due to the arm's length remuneration. As a result, the business profits from reinsurance activities had no tax implications in India, and the appeal was allowed in favor of the appellant. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429607