https://www.taxtmi.com/caselaws?id=793605 Reinsurance premium remitted to overseas reinsurance entities was held not taxable in India where the revenue failed to establish that Indian subsidiaries were the foreign entities' permanent establishments. The coordinate bench view was followed that the subsidiaries did not render reinsurance services to the payer and no factual basis existed for attributing the receipts to a PE. The payments were also found to be pure reinsurance premium, with no material to treat them as fees for technical services or royalty. Accordingly, no withholding tax obligation arose and the assessee could not be treated as an assessee in default under section 201. en-us Wed, 17 Jun 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793605 Reinsurance premium remitted to overseas reinsurance entities was held not taxable in India where the revenue failed to establish that Indian subsidiaries were the foreign entities' permanent establishments. The coordinate bench view was followed that the subsidiaries did not render reinsurance services to the payer and no factual basis existed for attributing the receipts to a PE. The payments were also found to be pure reinsurance premium, with no material to treat them as fees for technical services or royalty. Accordingly, no withholding tax obligation arose and the assessee could not be treated as an assessee in default under section 201. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793605