https://www.taxtmi.com/caselaws?id=779630 Permanent establishment requires proof that premises are at the foreign enterprise's disposal, that services are furnished within India, or that an Indian affiliate habitually has authority to conclude contracts; absent such evidence, no business profits are attributable in India. Link or IPLC charges were treated as payment for communication services, not royalty, because the payer obtained no possession, control, or legally significant right to use equipment. The earlier Mutual Agreement Procedure determination was treated as concluded in 2017 and was not applied as binding for assessment year 2022-23. The discussion notes relief on the permanent establishment, attribution, and MAP issues, while the royalty issue was decided against the assessee. en-us Tue, 30 Sep 2025 00:00:00 +0530 Wed, 08 Oct 2025 13:11:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779630 Permanent establishment requires proof that premises are at the foreign enterprise's disposal, that services are furnished within India, or that an Indian affiliate habitually has authority to conclude contracts; absent such evidence, no business profits are attributable in India. Link or IPLC charges were treated as payment for communication services, not royalty, because the payer obtained no possession, control, or legally significant right to use equipment. The earlier Mutual Agreement Procedure determination was treated as concluded in 2017 and was not applied as binding for assessment year 2022-23. The discussion notes relief on the permanent establishment, attribution, and MAP issues, while the royalty issue was decided against the assessee. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779630