https://www.taxtmi.com/highlights?id=101526 Offshore principal-to-principal sales of cars were held not taxable in India because the Indian distributor was an independent entity and did not constitute either a fixed place permanent establishment or a dependent agent permanent establishment under Article 5 of the India-Germany DTAA. The cars were manufactured outside India and sold outside India, and the Revenue could not show any distinguishing factual or legal feature from earlier co-ordinate Bench rulings in the assessee's own case. As no PE existed, the addition treating the business income as taxable in India was unsustainable, and attribution and related computation did not survive; consequential relief followed. en-us Thu, 09 Jul 2026 08:35:36 +0530 Thu, 09 Jul 2026 08:35:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101526 Offshore principal-to-principal sales of cars were held not taxable in India because the Indian distributor was an independent entity and did not constitute either a fixed place permanent establishment or a dependent agent permanent establishment under Article 5 of the India-Germany DTAA. The cars were manufactured outside India and sold outside India, and the Revenue could not show any distinguishing factual or legal feature from earlier co-ordinate Bench rulings in the assessee's own case. As no PE existed, the addition treating the business income as taxable in India was unsustainable, and attribution and related computation did not survive; consequential relief followed. Highlights Income Tax Thu, 09 Jul 2026 08:35:36 +0530 https://www.taxtmi.com/highlights?id=101526