Reinsurance Income Not Taxable in India: Tribunal Finds No Permanent Establishment, Overturns AO's Additions.

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....Income deemed to accrue or arise in India - reinsurance premium - Permanent Establishment (PE) in India or not - The Tribunal allowed the appeal, rejecting the additions made by the AO and directing that the Appellant's income related to reinsurance premiums and service fees from the specified Assessment Year is not taxable in India. The decision detailed the judicial precedence and interpretations of DTAA provisions critical in determining the tax obligations of multinational enterprises operating in multiple jurisdictions.....