https://www.taxtmi.com/caselaws?id=448389 The Indian company was not a fixed place permanent establishment of the foreign assessee because the treaty conditions were not satisfied: the Indian premises were not shown to be at the foreign assessee's disposal, and the foreign assessee did not carry on its business through those premises. The composite arrangement separately demarcated offshore and onshore activities through distinct cost centres and separate invoicing, and the issue was covered by the assessee's earlier year case. As a result, profits from offshore supply of sub-assemblies could not be attributed to an alleged Indian PE, and the addition was unsustainable. en-us Wed, 15 Nov 2023 00:00:00 +0530 Wed, 17 Jan 2024 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448389 The Indian company was not a fixed place permanent establishment of the foreign assessee because the treaty conditions were not satisfied: the Indian premises were not shown to be at the foreign assessee's disposal, and the foreign assessee did not carry on its business through those premises. The composite arrangement separately demarcated offshore and onshore activities through distinct cost centres and separate invoicing, and the issue was covered by the assessee's earlier year case. As a result, profits from offshore supply of sub-assemblies could not be attributed to an alleged Indian PE, and the addition was unsustainable. Case-Laws Income Tax Wed, 15 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448389