https://www.taxtmi.com/highlights?id=102836 Service permanent establishment analysis under the India-USA DTAA requires services to be furnished through employees or other personnel and excludes services covered as royalties or fees for included services. Stewardship, oversight and other auxiliary activities do not establish a service PE unless the nature of training, administrative, news-gathering or sales-support functions is shown to exceed auxiliary activity or to constitute technical or consultancy services. A distributor operating independently on a principal-to-principal basis, without authority to conclude contracts, maintain delivery stock or habitually secure orders, does not constitute a dependent agent PE. Where intercompany dealings are at arm's length, no further profit is attributable to an alleged PE. en-us Wed, 19 Aug 2026 08:20:11 +0530 Wed, 19 Aug 2026 08:20:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102836 Service permanent establishment analysis under the India-USA DTAA requires services to be furnished through employees or other personnel and excludes services covered as royalties or fees for included services. Stewardship, oversight and other auxiliary activities do not establish a service PE unless the nature of training, administrative, news-gathering or sales-support functions is shown to exceed auxiliary activity or to constitute technical or consultancy services. A distributor operating independently on a principal-to-principal basis, without authority to conclude contracts, maintain delivery stock or habitually secure orders, does not constitute a dependent agent PE. Where intercompany dealings are at arm's length, no further profit is attributable to an alleged PE. Highlights Income Tax Wed, 19 Aug 2026 08:20:11 +0530 https://www.taxtmi.com/highlights?id=102836