https://www.taxtmi.com/caselaws?id=795749 Under the India-Singapore tax treaty, an Indian business connection or permanent establishment was not established on the identical facts addressed. Where the Indian entity has received arm's-length remuneration and no separate transfer-pricing adjustment is made, no additional profits may be attributed to an alleged dependent-agent permanent establishment. Interest on an income-tax refund that is not effectively connected with the permanent establishment falls under the treaty provision governing interest income, rather than domestic charging provisions. These principles support relief from further profit attribution and treaty-based taxation of the refund interest. en-us Wed, 24 Jun 2026 00:00:00 +0530 Mon, 27 Jul 2026 08:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795749 Under the India-Singapore tax treaty, an Indian business connection or permanent establishment was not established on the identical facts addressed. Where the Indian entity has received arm's-length remuneration and no separate transfer-pricing adjustment is made, no additional profits may be attributed to an alleged dependent-agent permanent establishment. Interest on an income-tax refund that is not effectively connected with the permanent establishment falls under the treaty provision governing interest income, rather than domestic charging provisions. These principles support relief from further profit attribution and treaty-based taxation of the refund interest. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795749