https://www.taxtmi.com/caselaws?id=785228 A dependent agent permanent establishment was not established where the Indian subsidiary bought products on its own account, acted as an independent contractor, bore market, credit and inventory risks, and had no authority to bind the foreign enterprise; attribution of offshore sales income was therefore deleted. Reimbursements for software, IT support, cloud facilities, email hosting and related group services were treated as consideration for managerial services, not a pure cost-to-cost pass-through, and were held taxable as fees for technical services under the treaty and domestic law. The assessee obtained relief on the permanent establishment issue but failed on the fees for technical services issue. en-us Tue, 13 Jan 2026 00:00:00 +0530 Tue, 20 Jan 2026 06:31:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785228 A dependent agent permanent establishment was not established where the Indian subsidiary bought products on its own account, acted as an independent contractor, bore market, credit and inventory risks, and had no authority to bind the foreign enterprise; attribution of offshore sales income was therefore deleted. Reimbursements for software, IT support, cloud facilities, email hosting and related group services were treated as consideration for managerial services, not a pure cost-to-cost pass-through, and were held taxable as fees for technical services under the treaty and domestic law. The assessee obtained relief on the permanent establishment issue but failed on the fees for technical services issue. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785228