https://www.taxtmi.com/caselaws?id=468630 A foreign reinsurer's Indian tax exposure depends on whether its support arrangements create a fixed place, service or dependent agent permanent establishment; where underwriting and risk functions are carried out outside India and Indian affiliates act as independent service providers on an arm's length basis, the premium income is treated as not taxable in India as business profits. Support, administrative and coordination services are not fees for technical services unless they make technical knowledge, skill, experience, know-how or processes available for independent use by the recipient. TDS credit, interest under section 244A and refund adjustment claims may require verification against departmental records and Form 26AS before consequential relief. en-us Thu, 20 Nov 2025 00:00:00 +0530 Thu, 14 May 2026 19:45:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468630 A foreign reinsurer's Indian tax exposure depends on whether its support arrangements create a fixed place, service or dependent agent permanent establishment; where underwriting and risk functions are carried out outside India and Indian affiliates act as independent service providers on an arm's length basis, the premium income is treated as not taxable in India as business profits. Support, administrative and coordination services are not fees for technical services unless they make technical knowledge, skill, experience, know-how or processes available for independent use by the recipient. TDS credit, interest under section 244A and refund adjustment claims may require verification against departmental records and Form 26AS before consequential relief. Case-Laws Income Tax Thu, 20 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468630