https://www.taxtmi.com/caselaws?id=782445 Indian tax exposure for a fixed place permanent establishment turns on whether the foreign enterprise had a place at its disposal and carried on business through it with sufficient stability, productivity and dependence. The discussion notes that Article 5(4) and the concept of a dependent agent permanent establishment require concrete evidence of a collaborative exercise creating a fixed place PE, not mere assertions. It also records that reassessment notices under sections 147 and 148 were criticised for lacking material to show that a fixed place PE had come into existence. The text further refers to the Delhi High Court's explanation of the relevant PE tests and the phrases "at the disposal of" and "through". en-us Fri, 21 Nov 2025 00:00:00 +0530 Tue, 14 Jul 2026 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782445 Indian tax exposure for a fixed place permanent establishment turns on whether the foreign enterprise had a place at its disposal and carried on business through it with sufficient stability, productivity and dependence. The discussion notes that Article 5(4) and the concept of a dependent agent permanent establishment require concrete evidence of a collaborative exercise creating a fixed place PE, not mere assertions. It also records that reassessment notices under sections 147 and 148 were criticised for lacking material to show that a fixed place PE had come into existence. The text further refers to the Delhi High Court's explanation of the relevant PE tests and the phrases "at the disposal of" and "through". Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782445