https://www.taxtmi.com/caselaws?id=800568 Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for conducting its business; group-wide filings and website information do not suffice. Dependent agency permanent establishment requires material showing that the subsidiary habitually concludes contracts, maintains and delivers stock, or habitually secures orders for the foreign enterprise. An independently operating manufacturer dealing on a principal-to-principal basis and bearing business risks does not satisfy these conditions. A royalty licensing arrangement does not establish agency for distinct offshore supply transactions. No profits from those supplies are attributable in India absent either form of permanent establishment. en-us Wed, 23 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800568 Fixed place permanent establishment requires evidence that the foreign enterprise has a right to use or control the Indian subsidiary's premises for conducting its business; group-wide filings and website information do not suffice. Dependent agency permanent establishment requires material showing that the subsidiary habitually concludes contracts, maintains and delivers stock, or habitually secures orders for the foreign enterprise. An independently operating manufacturer dealing on a principal-to-principal basis and bearing business risks does not satisfy these conditions. A royalty licensing arrangement does not establish agency for distinct offshore supply transactions. No profits from those supplies are attributable in India absent either form of permanent establishment. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800568