https://www.taxtmi.com/forum/issue?id=121064 Permanent-establishment disclosure in ITR-3 for a non-resident independent consultant working from India is fact-sensitive. Working from a residence does not automatically create a PE. Relevant factors include dedicated premises, use of the address for GST or invoicing, client access, authority to conclude contracts, employees or subcontractors, separate office premises, business continuity and home-office expenses. PE and the India-US DTAA fixed-base concept for independent professional services are distinct. Section 92F should not be mechanically applied outside its transfer-pricing context. The position should be supported by contemporaneous documentation and treaty-residence analysis where relevant. en-us Tue, 11 Aug 2026 12:06:09 +0530 Wed, 12 Aug 2026 15:35:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=121064 Permanent-establishment disclosure in ITR-3 for a non-resident independent consultant working from India is fact-sensitive. Working from a residence does not automatically create a PE. Relevant factors include dedicated premises, use of the address for GST or invoicing, client access, authority to conclude contracts, employees or subcontractors, separate office premises, business continuity and home-office expenses. PE and the India-US DTAA fixed-base concept for independent professional services are distinct. Section 92F should not be mechanically applied outside its transfer-pricing context. The position should be supported by contemporaneous documentation and treaty-residence analysis where relevant. Discussion-Forum Income Tax Tue, 11 Aug 2026 12:06:09 +0530 https://www.taxtmi.com/forum/issue?id=121064