https://www.taxtmi.com/caselaws?id=791739 A foreign reinsurer's receipts from reinsurance and retrocession were analysed on the basis that the core risk assumption and capital deployment functions were carried on outside India, while Indian entities acted as independent service providers and their premises were not at the assessee's disposal. On those facts, no fixed place, service or dependent agent permanent establishment arose, and the domestic law test of business connection was also not met, so the receipts were not taxable in India as business profits. The support-service payments were treated as managerial and coordination functions, but they did not make available technical knowledge, skill, experience or know-how to the Indian recipients, so they were not Fees for Technical Services and were not taxable in India. en-us Mon, 27 Apr 2026 00:00:00 +0530 Sat, 16 May 2026 09:09:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791739 A foreign reinsurer's receipts from reinsurance and retrocession were analysed on the basis that the core risk assumption and capital deployment functions were carried on outside India, while Indian entities acted as independent service providers and their premises were not at the assessee's disposal. On those facts, no fixed place, service or dependent agent permanent establishment arose, and the domestic law test of business connection was also not met, so the receipts were not taxable in India as business profits. The support-service payments were treated as managerial and coordination functions, but they did not make available technical knowledge, skill, experience or know-how to the Indian recipients, so they were not Fees for Technical Services and were not taxable in India. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791739