https://www.taxtmi.com/caselaws?id=752527 Reinsurance and retrocession receipts were held not taxable in India because the DRP had already accepted the assessee's position on identical facts in a sister concern's case, and that finding bound the Assessing Officer under section 144C(13); the competing arguments on business connection, fixed place, service or agency permanent establishment, and profit attribution were therefore academic. Service fees from Indian group entities were also held outside the treaty fee for technical services clause because the services did not make available technical knowledge, skill, experience or know-how enabling independent future use by the recipients. The additions on both counts were deleted. en-us Wed, 17 Jan 2024 00:00:00 +0530 Sat, 11 May 2024 09:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752527 Reinsurance and retrocession receipts were held not taxable in India because the DRP had already accepted the assessee's position on identical facts in a sister concern's case, and that finding bound the Assessing Officer under section 144C(13); the competing arguments on business connection, fixed place, service or agency permanent establishment, and profit attribution were therefore academic. Service fees from Indian group entities were also held outside the treaty fee for technical services clause because the services did not make available technical knowledge, skill, experience or know-how enabling independent future use by the recipients. The additions on both counts were deleted. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752527