https://www.taxtmi.com/caselaws?id=435396 The article notes that the ITAT Delhi reiterated, in the assessee's own prior years' case, that the Revenue had not proved a fixed place PE or dependent agent PE in India. It relied on unchanged facts, including direct sales from Singapore, no visits by the assessee's employees to India, and agreements that did not authorise the Indian entity to conclude contracts on the assessee's behalf. On that footing, the analysis states that business profits could not be taxed in India in the absence of a PE, and attribution of profits to the alleged PE was unsustainable. 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 The article notes that the ITAT Delhi reiterated, in the assessee's own prior years' case, that the Revenue had not proved a fixed place PE or dependent agent PE in India. It relied on unchanged facts, including direct sales from Singapore, no visits by the assessee's employees to India, and agreements that did not authorise the Indian entity to conclude contracts on the assessee's behalf. On that footing, the analysis states that business profits could not be taxed in India in the absence of a PE, and attribution of profits to the alleged PE was unsustainable. Case-Laws Income Tax Fri, 17 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435396