https://www.taxtmi.com/caselaws?id=774591 Support and ancillary functions carried out in India did not, on the facts recorded, create a fixed place or dependent agent permanent establishment, business connection, or taxable presence for reinsurance receipts where the core risk was assumed outside India and contracts were concluded outside India. The anti-fragmentation rule under the MLI was found inapplicable because the Indian entity and the foreign reinsurer were not shown to carry on complementary activities forming a cohesive business operation in India. The alleged Indian taxation nexus was deleted. The interest claim under section 244A was directed to be recomputed afresh and restored for reconsideration in light of the substantive result. en-us Wed, 25 Jun 2025 00:00:00 +0530 Wed, 09 Jul 2025 11:52:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774591 Support and ancillary functions carried out in India did not, on the facts recorded, create a fixed place or dependent agent permanent establishment, business connection, or taxable presence for reinsurance receipts where the core risk was assumed outside India and contracts were concluded outside India. The anti-fragmentation rule under the MLI was found inapplicable because the Indian entity and the foreign reinsurer were not shown to carry on complementary activities forming a cohesive business operation in India. The alleged Indian taxation nexus was deleted. The interest claim under section 244A was directed to be recomputed afresh and restored for reconsideration in light of the substantive result. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774591