https://www.taxtmi.com/caselaws?id=456977 Reinsurance premium paid to non-resident reinsurers was treated as business income of the foreign recipients, but it was not taxable in India because the Revenue failed to show receipt in India, accrual or deemed accrual in India, a business connection, or a permanent establishment. The reinsurance brokers were only facilitators or independent service providers and were not agents concluding contracts for the reinsurers. Mere routing of payments through Indian brokers did not create taxable receipt in India. As no tax was deductible at source on the remittance, the disallowance for non-deduction of tax was deleted. en-us Fri, 26 Aug 2022 00:00:00 +0530 Thu, 29 Aug 2024 21:49:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456977 Reinsurance premium paid to non-resident reinsurers was treated as business income of the foreign recipients, but it was not taxable in India because the Revenue failed to show receipt in India, accrual or deemed accrual in India, a business connection, or a permanent establishment. The reinsurance brokers were only facilitators or independent service providers and were not agents concluding contracts for the reinsurers. Mere routing of payments through Indian brokers did not create taxable receipt in India. As no tax was deductible at source on the remittance, the disallowance for non-deduction of tax was deleted. Case-Laws Income Tax Fri, 26 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456977