https://www.taxtmi.com/caselaws?id=752386 A foreign reinsurer carried on underwriting outside India and the Indian support entity performed only ancillary communication, claims and data functions on an arm's length basis, so no fixed place PE, dependent agent PE or taxable business connection arose in India. The absence of premises at the assessee's disposal, core risk-bearing activity in India, authority to conclude contracts, or assumption of risk by the Indian entity was decisive. The Multilateral Instrument was held inapplicable to the year under consideration because its relevant Indian effect began only from 1 April 2020. Additional TDS credit was allowed as claimed in the return, subject to verification in the prescribed manner. en-us Wed, 31 Jan 2024 00:00:00 +0530 Wed, 08 May 2024 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752386 A foreign reinsurer carried on underwriting outside India and the Indian support entity performed only ancillary communication, claims and data functions on an arm's length basis, so no fixed place PE, dependent agent PE or taxable business connection arose in India. The absence of premises at the assessee's disposal, core risk-bearing activity in India, authority to conclude contracts, or assumption of risk by the Indian entity was decisive. The Multilateral Instrument was held inapplicable to the year under consideration because its relevant Indian effect began only from 1 April 2020. Additional TDS credit was allowed as claimed in the return, subject to verification in the prescribed manner. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752386