https://www.taxtmi.com/caselaws?id=796680 Permanent establishment status requires the Revenue to prove that an Indian office of an affiliated entity was at the foreign enterprise's disposal, used for its business, or habitually exercised authority to conclude contracts or secure orders on its behalf. The project office did not meet the conditions for either a fixed place or dependent agent permanent establishment. Separately contracted offshore equipment supply, repair and refurbishment performed outside India, with title passing outside India, lacked an Indian taxable nexus where the contractual separation was not shown to be artificial. Accordingly, offshore receipts were not taxable in India and no profit was attributable to an alleged Indian permanent establishment. en-us Mon, 03 Aug 2026 00:00:00 +0530 Sat, 08 Aug 2026 08:32:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796680 Permanent establishment status requires the Revenue to prove that an Indian office of an affiliated entity was at the foreign enterprise's disposal, used for its business, or habitually exercised authority to conclude contracts or secure orders on its behalf. The project office did not meet the conditions for either a fixed place or dependent agent permanent establishment. Separately contracted offshore equipment supply, repair and refurbishment performed outside India, with title passing outside India, lacked an Indian taxable nexus where the contractual separation was not shown to be artificial. Accordingly, offshore receipts were not taxable in India and no profit was attributable to an alleged Indian permanent establishment. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796680