https://www.taxtmi.com/caselaws?id=797234 Service permanent establishment requires proof that personnel furnished qualifying services in India beyond auxiliary functions and outside treaty exclusions for technical or consultancy services. Oversight, training, administrative support, news-gathering assistance and product-sales support did not establish such a presence where the activities were auxiliary or potentially excluded. A subsidiary was not a dependent agent permanent establishment because it independently contracted with customers, invoiced them and assumed contractual responsibilities on a principal-to-principal basis; parental controls and exclusive distribution did not alter that character. Arm's-length transfer-pricing acceptance further supported no additional profit attribution. No taxable profit was assessable in India on a permanent-establishment basis. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797234 Service permanent establishment requires proof that personnel furnished qualifying services in India beyond auxiliary functions and outside treaty exclusions for technical or consultancy services. Oversight, training, administrative support, news-gathering assistance and product-sales support did not establish such a presence where the activities were auxiliary or potentially excluded. A subsidiary was not a dependent agent permanent establishment because it independently contracted with customers, invoiced them and assumed contractual responsibilities on a principal-to-principal basis; parental controls and exclusive distribution did not alter that character. Arm's-length transfer-pricing acceptance further supported no additional profit attribution. No taxable profit was assessable in India on a permanent-establishment basis. Case-Laws Income Tax Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797234