https://www.taxtmi.com/caselaws?id=768235 The India-Mauritius DTAA dependent agent PE threshold was not met because the Indian shipping agent was not shown to be wholly or almost wholly devoted to the non-resident assessee, and the record did not establish authority to conclude contracts on the assessee's behalf. Its shipping-agency work for multiple principals, with substantial revenue from third parties and other shipping lines, indicated functional independence. Ordinary cargo booking, freight collection and similar agency functions were insufficient, by themselves, to create a dependent agent permanent establishment. The finding of no PE was therefore upheld and the Revenue's challenge failed. en-us Fri, 28 Mar 2025 00:00:00 +0530 Thu, 03 Apr 2025 07:50:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768235 The India-Mauritius DTAA dependent agent PE threshold was not met because the Indian shipping agent was not shown to be wholly or almost wholly devoted to the non-resident assessee, and the record did not establish authority to conclude contracts on the assessee's behalf. Its shipping-agency work for multiple principals, with substantial revenue from third parties and other shipping lines, indicated functional independence. Ordinary cargo booking, freight collection and similar agency functions were insufficient, by themselves, to create a dependent agent permanent establishment. The finding of no PE was therefore upheld and the Revenue's challenge failed. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768235