https://www.taxtmi.com/highlights?id=102592 Fixed place permanent establishment under the India-Thailand DTAA requires cogent evidence that the non-resident enterprise carried on its business through a place at its disposal in India. Survey material showing expatriates working with an Indian group company and receiving remuneration from a Japanese parent did not establish that they acted for the Thailand-based supplier, were deputed by it, or that it had a fixed place of business in India. Associated-enterprise status alone was insufficient to create a permanent establishment. On identical facts, the supplier was treated as having no permanent establishment in India, making the transfer-pricing grounds infructuous. en-us Tue, 11 Aug 2026 09:39:32 +0530 Tue, 11 Aug 2026 09:39:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102592 Fixed place permanent establishment under the India-Thailand DTAA requires cogent evidence that the non-resident enterprise carried on its business through a place at its disposal in India. Survey material showing expatriates working with an Indian group company and receiving remuneration from a Japanese parent did not establish that they acted for the Thailand-based supplier, were deputed by it, or that it had a fixed place of business in India. Associated-enterprise status alone was insufficient to create a permanent establishment. On identical facts, the supplier was treated as having no permanent establishment in India, making the transfer-pricing grounds infructuous. Highlights Income Tax Tue, 11 Aug 2026 09:39:32 +0530 https://www.taxtmi.com/highlights?id=102592