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of Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection - The Tribunal upheld that the assessee has a 'Business Connection' in India. However, it was determined that since the assessee compensated its Indian agents (ZTL and El-Zee) at an arm's length price, no further income from advertisement and subscription revenue is attributable to the assessee from operations carried out in India. - The Tribunal upheld the CIT(A)'s acceptance of the assessee's cash system of accounting, aligning with the consistency in the assessee's past accounting practices.
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