https://www.taxtmi.com/caselaws?id=435396 Permanent establishment requirements were not met because the Revenue did not establish either a fixed place PE or a dependent agent PE in India. Sales were made directly from Singapore, the assessee's employees did not visit India, and the Indian entity lacked authority to conclude contracts on the assessee's behalf. Consequently, business profits were not taxable in India in the absence of a PE, and profit attribution to the alleged PE was unsustainable. The profit-attribution additions were deleted. en-us Fri, 17 Mar 2023 00:00:00 +0530 Fri, 17 Mar 2023 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435396 Permanent establishment requirements were not met because the Revenue did not establish either a fixed place PE or a dependent agent PE in India. Sales were made directly from Singapore, the assessee's employees did not visit India, and the Indian entity lacked authority to conclude contracts on the assessee's behalf. Consequently, business profits were not taxable in India in the absence of a PE, and profit attribution to the alleged PE was unsustainable. The profit-attribution additions were deleted. Case-Laws Income Tax Fri, 17 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435396