https://www.taxtmi.com/caselaws?id=794313 Article 8 treaty relief under the India-Mauritius DTAA was denied where the assessee's place of effective management was found to be outside Mauritius and India, consistent with earlier years. Under Article 5, no fixed place PE or dependent agent PE arose in India because the Indian agent acted independently, served multiple principals, and no premises were at the assessee's disposal; occasional visits and use of web-based software were insufficient, so attribution or aggregation of income for PE purposes did not apply. Interest on income-tax refund was held taxable at the treaty rate under Article 11(2). en-us Tue, 30 Jun 2026 00:00:00 +0530 Fri, 03 Jul 2026 08:49:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794313 Article 8 treaty relief under the India-Mauritius DTAA was denied where the assessee's place of effective management was found to be outside Mauritius and India, consistent with earlier years. Under Article 5, no fixed place PE or dependent agent PE arose in India because the Indian agent acted independently, served multiple principals, and no premises were at the assessee's disposal; occasional visits and use of web-based software were insufficient, so attribution or aggregation of income for PE purposes did not apply. Interest on income-tax refund was held taxable at the treaty rate under Article 11(2). Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794313