https://www.taxtmi.com/caselaws?id=467428 Reinsurance premium received by a foreign enterprise was held not taxable in India because the Revenue failed to prove a business connection or fixed place permanent establishment. The liaison office was limited to communication and auxiliary support and could not undertake commercial, trading, insurance or reinsurance operations, while the Indian subsidiary only provided data collection, administrative and marketing support without negotiating, concluding or executing contracts, settling claims, or performing core underwriting functions. The subsidiary was also not a dependent agent permanent establishment because it lacked authority to bind the enterprise or secure business on its behalf. The additions treating the receipts as taxable in India were set aside. en-us Fri, 29 Oct 2021 00:00:00 +0530 Wed, 18 Mar 2026 17:59:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467428 Reinsurance premium received by a foreign enterprise was held not taxable in India because the Revenue failed to prove a business connection or fixed place permanent establishment. The liaison office was limited to communication and auxiliary support and could not undertake commercial, trading, insurance or reinsurance operations, while the Indian subsidiary only provided data collection, administrative and marketing support without negotiating, concluding or executing contracts, settling claims, or performing core underwriting functions. The subsidiary was also not a dependent agent permanent establishment because it lacked authority to bind the enterprise or secure business on its behalf. The additions treating the receipts as taxable in India were set aside. Case-Laws Income Tax Fri, 29 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467428