https://www.taxtmi.com/caselaws?id=448544 Pure reimbursement of laboratory testing charges was not fees for technical services because the recipient merely acted as a conduit and rendered no independent technical service; the addition was deleted. A permanent establishment in India was not established on the record, as the alleged nexus rested on assumption rather than evidence and no fixed place of business or other treaty-recognised presence in India was shown. In the absence of a permanent establishment, attribution of profits on a presumptive basis could not stand; that finding was set aside. en-us Mon, 20 Nov 2023 00:00:00 +0530 Sun, 21 Jan 2024 21:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448544 Pure reimbursement of laboratory testing charges was not fees for technical services because the recipient merely acted as a conduit and rendered no independent technical service; the addition was deleted. A permanent establishment in India was not established on the record, as the alleged nexus rested on assumption rather than evidence and no fixed place of business or other treaty-recognised presence in India was shown. In the absence of a permanent establishment, attribution of profits on a presumptive basis could not stand; that finding was set aside. Case-Laws Income Tax Mon, 20 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448544