https://www.taxtmi.com/caselaws?id=796680 A foreign enterprise does not acquire a fixed place or dependent agent permanent establishment merely because an affiliated entity maintains an Indian project office. Treaty conditions require evidence that the office was at the enterprise's disposal, used for its business, or habitually exercised contract-concluding or order-securing authority; the material described did not establish these conditions. Separately contracted offshore supplies, repairs and refurbishment performed outside India, with title passing outside India, lack an Indian taxable nexus where no Indian permanent establishment exists. The article states that the offshore-receipt addition and profit attribution to an alleged Indian presence could not be sustained. 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 A foreign enterprise does not acquire a fixed place or dependent agent permanent establishment merely because an affiliated entity maintains an Indian project office. Treaty conditions require evidence that the office was at the enterprise's disposal, used for its business, or habitually exercised contract-concluding or order-securing authority; the material described did not establish these conditions. Separately contracted offshore supplies, repairs and refurbishment performed outside India, with title passing outside India, lack an Indian taxable nexus where no Indian permanent establishment exists. The article states that the offshore-receipt addition and profit attribution to an alleged Indian presence could not be sustained. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796680