https://www.taxtmi.com/caselaws?id=462691 Foreign reinsurance operations did not create a business connection or permanent establishment in India where the core risk-assumption activity was undertaken outside India and the Indian associated entity provided arm's-length support services. The Indian entity neither constituted a fixed place permanent establishment nor a dependent agent permanent establishment on the stated facts. The anti-fragmentation rule under the modified treaty provision applies only where source-State activities are complementary functions forming part of a cohesive business operation. As the foreign reinsurer had no premises or business operations in India and the support services were not part of such a combined operation, the amended permanent establishment rule did not apply. The related income was not taxable in India on that basis. en-us Wed, 22 May 2024 00:00:00 +0530 Wed, 09 Jul 2025 12:54:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462691 Foreign reinsurance operations did not create a business connection or permanent establishment in India where the core risk-assumption activity was undertaken outside India and the Indian associated entity provided arm's-length support services. The Indian entity neither constituted a fixed place permanent establishment nor a dependent agent permanent establishment on the stated facts. The anti-fragmentation rule under the modified treaty provision applies only where source-State activities are complementary functions forming part of a cohesive business operation. As the foreign reinsurer had no premises or business operations in India and the support services were not part of such a combined operation, the amended permanent establishment rule did not apply. The related income was not taxable in India on that basis. Case-Laws Income Tax Wed, 22 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462691