https://www.taxtmi.com/caselaws?id=794660 Indian distributor was treated as an independent principal-to-principal reseller, so no fixed place PE or dependent agent PE was established in India. The Tribunal noted that manufacture and sale were completed outside India and that the Revenue produced no material showing that the distributor was a fixed place of business of the assessee or habitually concluded contracts on its behalf. As no business connection or permanent establishment was proved, income from offshore vehicle and component sales was not taxable in India, and attribution and interest issues did not require separate examination. en-us Wed, 10 Jun 2026 00:00:00 +0530 Thu, 09 Jul 2026 08:35:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794660 Indian distributor was treated as an independent principal-to-principal reseller, so no fixed place PE or dependent agent PE was established in India. The Tribunal noted that manufacture and sale were completed outside India and that the Revenue produced no material showing that the distributor was a fixed place of business of the assessee or habitually concluded contracts on its behalf. As no business connection or permanent establishment was proved, income from offshore vehicle and component sales was not taxable in India, and attribution and interest issues did not require separate examination. Case-Laws Income Tax Wed, 10 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794660