https://www.taxtmi.com/caselaws?id=792919 A fixed place permanent establishment under the India-Canada DTAA requires a place of business at the enterprise's disposal, permanence, and business carried on through that place; mere access to customer premises for project-specific work was insufficient, so no fixed place permanent establishment existed in India. An installation or supervisory permanent establishment also was not constituted because the relevant activities did not exceed the treaty's 120-day threshold in the 12-month period; accordingly, no income could be attributed on that basis. The additions based on the alleged permanent establishment were therefore unsustainable and the assessee's appeal succeeded. en-us Wed, 03 Jun 2026 00:00:00 +0530 Fri, 05 Jun 2026 08:07:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792919 A fixed place permanent establishment under the India-Canada DTAA requires a place of business at the enterprise's disposal, permanence, and business carried on through that place; mere access to customer premises for project-specific work was insufficient, so no fixed place permanent establishment existed in India. An installation or supervisory permanent establishment also was not constituted because the relevant activities did not exceed the treaty's 120-day threshold in the 12-month period; accordingly, no income could be attributed on that basis. The additions based on the alleged permanent establishment were therefore unsustainable and the assessee's appeal succeeded. Case-Laws Income Tax Wed, 03 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792919