https://www.taxtmi.com/caselaws?id=766443 The article explains that a foreign enterprise was held not to have a Fixed Place Permanent Establishment in India where its liaison operations and Indian subsidiary performed separate installation, marketing and technical support functions under independent contracts, with offshore supply on a principal-to-principal basis. It also states that the subsidiary was not a Dependent Agent Permanent Establishment because it lacked authority to bind the foreign enterprise or habitually conclude contracts for it. On income characterization, notional interest on delayed consideration was held not taxable in the absence of actual accrual or an enforceable claim, and software supply revenue was treated as payment for a copyrighted article, not royalty or fee for technical services. en-us Fri, 21 Feb 2025 00:00:00 +0530 Mon, 09 Feb 2026 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766443 The article explains that a foreign enterprise was held not to have a Fixed Place Permanent Establishment in India where its liaison operations and Indian subsidiary performed separate installation, marketing and technical support functions under independent contracts, with offshore supply on a principal-to-principal basis. It also states that the subsidiary was not a Dependent Agent Permanent Establishment because it lacked authority to bind the foreign enterprise or habitually conclude contracts for it. On income characterization, notional interest on delayed consideration was held not taxable in the absence of actual accrual or an enforceable claim, and software supply revenue was treated as payment for a copyrighted article, not royalty or fee for technical services. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766443