https://www.taxtmi.com/caselaws?id=310966 A fixed place permanent establishment in India requires premises to be at the disposal of the foreign enterprise and used for carrying on its business. On the facts, no Indian premises were shown to be at the assessee's disposal, and the Indian affiliate's support services were separately remunerated at arm's length, so no additional business profit could be attributed in India on that basis. The dependent agent permanent establishment point was treated as academic and tax neutral. The TDS credit claim was not decided on merits and was sent back to the Assessing Officer for verification and allowance in accordance with law, leaving the remaining grounds academic. en-us Tue, 02 May 2023 00:00:00 +0530 Tue, 28 Nov 2023 17:52:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310966 A fixed place permanent establishment in India requires premises to be at the disposal of the foreign enterprise and used for carrying on its business. On the facts, no Indian premises were shown to be at the assessee's disposal, and the Indian affiliate's support services were separately remunerated at arm's length, so no additional business profit could be attributed in India on that basis. The dependent agent permanent establishment point was treated as academic and tax neutral. The TDS credit claim was not decided on merits and was sent back to the Assessing Officer for verification and allowance in accordance with law, leaving the remaining grounds academic. Case-Laws Income Tax Tue, 02 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310966