https://www.taxtmi.com/highlights?id=104691 Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for its business; group-wide Form 10-K and website material do not establish that condition. A subsidiary relationship alone is insufficient. Dependent agency permanent establishment also requires authority to conclude contracts or habitual order securing for the foreign enterprise. Independent principal-to-principal dealings, the subsidiary's separate manufacturing operations, and a licence arrangement confined to royalty-bearing products did not satisfy those conditions. Neither form of permanent establishment arose, so no Indian profits were attributable to the disputed offshore supplies and the attribution was deleted. en-us Thu, 08 Oct 2026 08:45:20 +0530 Thu, 08 Oct 2026 08:45:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104691 Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for its business; group-wide Form 10-K and website material do not establish that condition. A subsidiary relationship alone is insufficient. Dependent agency permanent establishment also requires authority to conclude contracts or habitual order securing for the foreign enterprise. Independent principal-to-principal dealings, the subsidiary's separate manufacturing operations, and a licence arrangement confined to royalty-bearing products did not satisfy those conditions. Neither form of permanent establishment arose, so no Indian profits were attributable to the disputed offshore supplies and the attribution was deleted. Highlights Income Tax Thu, 08 Oct 2026 08:45:20 +0530 https://www.taxtmi.com/highlights?id=104691