https://www.taxtmi.com/caselaws?id=796822 Permanent establishment under Article 5 of the India-Thailand DTAA was not established because no cogent material showed that employees of the Indian affiliate acted for the Thai assessee, that the assessee deputed personnel to India, or that it had a fixed place of business at its disposal in India. Survey statements concerning expatriates and remuneration paid by a Japanese parent did not prove a taxable presence for the assessee. Goods were supplied and services rendered offshore from Thailand. Earlier years involving materially identical facts had likewise found no permanent establishment, supporting non-taxability of the offshore activities in India. en-us Thu, 06 Aug 2026 00:00:00 +0530 Tue, 11 Aug 2026 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796822 Permanent establishment under Article 5 of the India-Thailand DTAA was not established because no cogent material showed that employees of the Indian affiliate acted for the Thai assessee, that the assessee deputed personnel to India, or that it had a fixed place of business at its disposal in India. Survey statements concerning expatriates and remuneration paid by a Japanese parent did not prove a taxable presence for the assessee. Goods were supplied and services rendered offshore from Thailand. Earlier years involving materially identical facts had likewise found no permanent establishment, supporting non-taxability of the offshore activities in India. Case-Laws Income Tax Thu, 06 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796822