https://www.taxtmi.com/caselaws?id=791799 Under the India-Canada DTAA, remote access to customers' theatre systems for maintenance and troubleshooting did not create a fixed place permanent establishment because the customers' premises were not at the assessee's disposal and the required nexus with a place of business was absent. The Tribunal also found no service or supervisory permanent establishment, as services were rendered for only 67 days, below the treaty's 90-day threshold, and there was no physical presence of personnel in India. It rejected an attempt to infer employment from a LinkedIn profile and declined to recognise a virtual permanent establishment without express treaty language. en-us Wed, 13 May 2026 00:00:00 +0530 Mon, 18 May 2026 08:40:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791799 Under the India-Canada DTAA, remote access to customers' theatre systems for maintenance and troubleshooting did not create a fixed place permanent establishment because the customers' premises were not at the assessee's disposal and the required nexus with a place of business was absent. The Tribunal also found no service or supervisory permanent establishment, as services were rendered for only 67 days, below the treaty's 90-day threshold, and there was no physical presence of personnel in India. It rejected an attempt to infer employment from a LinkedIn profile and declined to recognise a virtual permanent establishment without express treaty language. Case-Laws Income Tax Wed, 13 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791799