https://www.taxtmi.com/caselaws?id=470477 Under the India-Singapore tax treaty, a fixed place or dependent agency permanent establishment requires material showing that Indian premises were at the foreign enterprise's disposal, or that the Indian entity had authority to conclude contracts or habitually secured orders exclusively for it. The note states that sales-support, installation, warranty, distribution and marketing-support functions did not meet these tests where contracts were concluded from Singapore, employees did not visit India, and inventory was held under principal-to-principal distribution arrangements. It also notes that untested customer-employee statements could not establish a permanent establishment. On these facts, no Indian business profits were attributable to an alleged permanent establishment. 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 tax treaty, a fixed place or dependent agency permanent establishment requires material showing that Indian premises were at the foreign enterprise's disposal, or that the Indian entity had authority to conclude contracts or habitually secured orders exclusively for it. The note states that sales-support, installation, warranty, distribution and marketing-support functions did not meet these tests where contracts were concluded from Singapore, employees did not visit India, and inventory was held under principal-to-principal distribution arrangements. It also notes that untested customer-employee statements could not establish a permanent establishment. On these facts, no Indian business profits were attributable to an alleged permanent establishment. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470477