https://www.taxtmi.com/caselaws?id=766443 Permanent establishment requires objective evidence of a fixed place at the foreign enterprise's disposal, with control, stability, productivity and business dependence; corporate affiliation, shared premises and administrative support alone do not suffice. An Indian subsidiary performing installation, marketing and technical support under separate contracts did not create either a fixed-place or dependent-agent permanent establishment where it lacked authority to bind the foreign enterprise and earned separately taxed income. Notional interest on delayed consideration was not taxable without an enforceable right, actual charge or accrued debt. Software supply involving a copyrighted article rather than copyright transfer was not royalty or fees 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 Permanent establishment requires objective evidence of a fixed place at the foreign enterprise's disposal, with control, stability, productivity and business dependence; corporate affiliation, shared premises and administrative support alone do not suffice. An Indian subsidiary performing installation, marketing and technical support under separate contracts did not create either a fixed-place or dependent-agent permanent establishment where it lacked authority to bind the foreign enterprise and earned separately taxed income. Notional interest on delayed consideration was not taxable without an enforceable right, actual charge or accrued debt. Software supply involving a copyrighted article rather than copyright transfer was not royalty or fees for technical services. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766443