https://www.taxtmi.com/caselaws?id=786716 Direct-business reinsurance premiums were treated as not taxable in India where the Indian subsidiary only provided support services and had no authority to conclude contracts, settle claims, or carry out core reinsurance functions; the India Branch also had no role in that income stream. Inter-office allocations from the India Branch to head office for IT and management costs were not treated as fees for technical services because branch and head office were one taxable person and the treaty did not support separate FTS taxation on those facts. Interest on income-tax refund remained taxable only at the treaty rate, and surcharge and cess were not added under the India-Germany treaty framework. en-us Fri, 30 Jan 2026 00:00:00 +0530 Wed, 18 Mar 2026 11:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786716 Direct-business reinsurance premiums were treated as not taxable in India where the Indian subsidiary only provided support services and had no authority to conclude contracts, settle claims, or carry out core reinsurance functions; the India Branch also had no role in that income stream. Inter-office allocations from the India Branch to head office for IT and management costs were not treated as fees for technical services because branch and head office were one taxable person and the treaty did not support separate FTS taxation on those facts. Interest on income-tax refund remained taxable only at the treaty rate, and surcharge and cess were not added under the India-Germany treaty framework. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786716