https://www.taxtmi.com/caselaws?id=756654 SanDisk India was found not to constitute a dependent agent permanent establishment for the relevant year because the record did not show any related party transaction during the period, and the alleged survey material arose only after the acquisition date. The revenue also failed to produce documentary evidence that SanDisk India provided marketing support or acted on the assessee's behalf. In the absence of an established transaction or business nexus, the treatment of reimbursements as fees for technical services and the attribution of 30% of profits to India were held unsustainable, and the issue was decided in favour of the assessee. en-us Wed, 31 Jul 2024 00:00:00 +0530 Mon, 05 Jan 2026 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756654 SanDisk India was found not to constitute a dependent agent permanent establishment for the relevant year because the record did not show any related party transaction during the period, and the alleged survey material arose only after the acquisition date. The revenue also failed to produce documentary evidence that SanDisk India provided marketing support or acted on the assessee's behalf. In the absence of an established transaction or business nexus, the treatment of reimbursements as fees for technical services and the attribution of 30% of profits to India were held unsustainable, and the issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 31 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756654