https://www.taxtmi.com/caselaws?id=799134 Cost-to-cost reimbursements received from Indian associated enterprises for third-party event, legal, professional, employee welfare and recruitment expenses were not taxable in India where the underlying activities were performed remotely without employees or personnel being physically present in India. A service permanent establishment under Article 5(2)(l) of the India-USA tax treaty requires services to be furnished or performed in India through employees or other personnel for the stipulated duration. As those cumulative conditions were not met, no service permanent establishment arose and the reimbursements did not constitute income chargeable to tax in India. en-us Thu, 27 Aug 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799134 Cost-to-cost reimbursements received from Indian associated enterprises for third-party event, legal, professional, employee welfare and recruitment expenses were not taxable in India where the underlying activities were performed remotely without employees or personnel being physically present in India. A service permanent establishment under Article 5(2)(l) of the India-USA tax treaty requires services to be furnished or performed in India through employees or other personnel for the stipulated duration. As those cumulative conditions were not met, no service permanent establishment arose and the reimbursements did not constitute income chargeable to tax in India. Case-Laws Income Tax Thu, 27 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799134