https://www.taxtmi.com/caselaws?id=470477 Under the India-Singapore DTAA, an Indian associated enterprise performing sales support, installation, warranty, distribution and marketing support does not create a fixed place or dependent agency permanent establishment where it lacks authority to negotiate or conclude contracts, direct sales are made from Singapore, and its premises are not at the foreign enterprise's disposal. Principal-to-principal inventory arrangements do not establish a warehouse or sales outlet of the foreign enterprise. Nor can customer-employee statements establish a permanent establishment without cross-examination. On these facts, no business profits are taxable in India through permanent establishment attribution. en-us Fri, 21 Mar 2025 00:00:00 +0530 Tue, 28 Jul 2026 19:00:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470477 Under the India-Singapore DTAA, an Indian associated enterprise performing sales support, installation, warranty, distribution and marketing support does not create a fixed place or dependent agency permanent establishment where it lacks authority to negotiate or conclude contracts, direct sales are made from Singapore, and its premises are not at the foreign enterprise's disposal. Principal-to-principal inventory arrangements do not establish a warehouse or sales outlet of the foreign enterprise. Nor can customer-employee statements establish a permanent establishment without cross-examination. On these facts, no business profits are taxable in India through permanent establishment attribution. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470477