Re-insurance profits not taxable in India as SRSIPL isn't a Permanent Establishment per India-Switzerland DTAA Article 7.

Taxability of income received from re-insurance business in India - since SRSIPL is not a PE of the assessee, the profits earned from re-insurance business cannot be brought to tax in India in terms of Article 7 of India Switzerland DTAA. Accordingly, addition is deleted. - AT .....

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