Reinsurance Activity Outside India: No Permanent Establishment, Tax Neutral Impact Under Indian Law.

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....Income deemed to accrue or arise in India - Permanent establishment (PE) in India - unless a particular place is at the disposal of the assessee, that place cannot be said to constitute the PE of the assessee. In any case, the core reinsurance activity is the assumption of risk, and that assumption of risk has been done outside India. - the existence of the DAPE is wholly tax neutral in India - AT....