https://www.taxtmi.com/caselaws?id=467135 Permanent Establishment and royalty characterisation were the central issues: the Tribunal applied the disposal test and business-activity criteria and found no dispossession or control of premises, no aggregated furnishing of services by the enterprise's personnel, and no habitual contract-concluding or stock-maintaining agency, concluding that the local subsidiary qualified as an independent agent remunerated at arm's length and therefore did not create a fixed-place, service or agency PE; consequently no profits were attributable to a PE. On royalty, the Tribunal held that royalty arises only from contractual entitlement and regulatory permission; global-deal transfers did not constitute royalty and the enhanced notional attribution was deleted. en-us Fri, 02 Jan 2026 00:00:00 +0530 Tue, 03 Mar 2026 15:02:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467135 Permanent Establishment and royalty characterisation were the central issues: the Tribunal applied the disposal test and business-activity criteria and found no dispossession or control of premises, no aggregated furnishing of services by the enterprise's personnel, and no habitual contract-concluding or stock-maintaining agency, concluding that the local subsidiary qualified as an independent agent remunerated at arm's length and therefore did not create a fixed-place, service or agency PE; consequently no profits were attributable to a PE. On royalty, the Tribunal held that royalty arises only from contractual entitlement and regulatory permission; global-deal transfers did not constitute royalty and the enhanced notional attribution was deleted. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467135