Assessee, a licensed broker with IRDAI, was making payment of reinsurance premium received from Indian insurance company to non-resident reinsurers (NRRs). As per IRDA guidelines, assessee broker was entitled to work in conjecture with overseas co-broker which in instant case was AB, Singapore. Assessing Officer held that assessee was Dependent Agent Permanent Establishment (DAPE) of AB in India as per provisions of article 5 of India-Singapore DTAA, thus, premium paid by assessee to NRRs through AB was taxable in India and TDS was to be deducted on same.  Held that the  assessee is  an independent broker under IRDA and worked on ‘principal to principal’ basis with its co-broker and also worked with other several persons/entities. Assessee had earned majority of its brokerage income from NRRs without having any transaction with AB Singapore or  involvement of AB Singapore. On facts, assessee was not DAPE of AB Singapore in India. Not liable to deduct tax at source. (AY. 2016-17)