Held that when an agent is paid an arm’s length remuneration for services rendered the existence of a dependent agent permanent establishment is wholly tax neutral.
UPS Asia Group Pte. Ltd. v. ACIT (IT) (2022) 195 ITD 225 (Mum.)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent establishment-Agency PE-Agent is paid arm’s length remuneration-Tax neutral-Not taxable-DTAA-India-Singapore. [Art. 5]