Telecast rights payment lacked nexus with Indian PE, so no substantial question of law arose.

The Court held that the Tribunal's conclusion on the telecast-rights payment was based on concurrent factual findings and did not raise any substantial question of law. The assessee was a Singapore resident, the cricket-rights agreement was with another Singapore resident, and the payment was linked to broadcasting operations carried on from Singapore rather than any marketing activity or permanent establishment in India. Because there was no economic nexus between the payment and the Indian permanent establishment, the Tribunal's view was not perverse. The Revenue's challenge therefore failed.

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Issues: Whether the Tribunal's findings on the character of the payment for telecast rights and its nexus with the assessee's operations in India gave rise to any substantial question of law.

Analysis: The dismissal turned on concurrent factual findings that the assessee was a Singapore resident, the agreement for cricket rights was entered into with another Singapore resident, and the payment related to broadcasting operations carried on from Singapore. The Court held that the liability was connected with the assessee's Singapore business and not with any marketing activity or permanent establishment in India. It further held that the absence of an economic link between the payment and the Indian permanent establishment made the Tribunal's conclusion a factual one, not perverse, and therefore not giving rise to a substantial question of law.

Conclusion: No substantial question of law arose, and the Revenue's challenge failed.

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