https://www.taxtmi.com/caselaws?id=766967 An independent foreign representative engaged for multiple clients, without authority to conclude contracts for the assessee and without the degree of control needed under Article 5 of the India-USA DTAA, does not constitute a dependent agent permanent establishment; accordingly, no business income is attributable in India. Drawing and design receipts supplied from outside India and forming part of a composite overseas supply of plant, machinery and equipment are treated as part of the business transaction under Article 7, not as separate fees for technical services under Article 12 or section 9(1)(vii); in the absence of a permanent establishment, they are not separately taxable in India. en-us Tue, 25 Feb 2025 00:00:00 +0530 Fri, 07 Mar 2025 08:41:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766967 An independent foreign representative engaged for multiple clients, without authority to conclude contracts for the assessee and without the degree of control needed under Article 5 of the India-USA DTAA, does not constitute a dependent agent permanent establishment; accordingly, no business income is attributable in India. Drawing and design receipts supplied from outside India and forming part of a composite overseas supply of plant, machinery and equipment are treated as part of the business transaction under Article 7, not as separate fees for technical services under Article 12 or section 9(1)(vii); in the absence of a permanent establishment, they are not separately taxable in India. Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766967