This case note explains the Supreme Court’s decision in Assistant Director of Income Tax-I v. M/s E-Funds IT Solution Inc., which held that, in order to establish a fixed place permanent establishment in India, a fixed place of business, which is at the disposal of a foreign company, and through which the business has been carried on, must exist in India. A close association between a foreign parent company and its subsidiary company in India is irrelevant to the determination of a fixed place PE.