https://www.taxtmi.com/caselaws?id=446154 A foreign reinsurer carrying on business from Ireland was found not to have a fixed place permanent establishment in India because no place in India was shown to be at its disposal for carrying on business, and no dependent agent permanent establishment existed because the Indian support entity had no authority to conclude contracts or habitually secure orders. On attribution, the Indian entity had been separately remunerated on an arm's length cost-plus basis for support functions, and no basis was shown for further profit allocation to India because it did not assume the reinsurer's risks or deploy assets warranting additional attribution. The prior-year coordinate bench view was followed, and the TDS-credit matter for one year was remitted for verification. en-us Wed, 06 Sep 2023 00:00:00 +0530 Mon, 27 Nov 2023 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446154 A foreign reinsurer carrying on business from Ireland was found not to have a fixed place permanent establishment in India because no place in India was shown to be at its disposal for carrying on business, and no dependent agent permanent establishment existed because the Indian support entity had no authority to conclude contracts or habitually secure orders. On attribution, the Indian entity had been separately remunerated on an arm's length cost-plus basis for support functions, and no basis was shown for further profit allocation to India because it did not assume the reinsurer's risks or deploy assets warranting additional attribution. The prior-year coordinate bench view was followed, and the TDS-credit matter for one year was remitted for verification. Case-Laws Income Tax Wed, 06 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446154