No Permanent Establishment in India: RGA Services Not a Dependent Agent for Tax Purposes.

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....Accrual of Income in India - Dependent Agent - PE in India or not? - DR has not brought on any material to show that RGA Services has utilized its assets or assumed any risk in this line of reinsurance business. Merely because its whole functions are depend on the services which will be utilized by the Foreign principal does not make it as an dependent agent. - AT....