https://www.taxtmi.com/caselaws?id=122366 A foreign telecasting company's advertisement revenue was examined under section 9(1)(i) of the Income-tax Act and article 7(1) of the applicable treaty to determine the extent of Indian tax attribution. The Indian entity performed only marketing services for airtime and was paid arm's length remuneration. On that basis, the profit attributable to the Indian activity was treated as exhausted by the arm's length service fee, so no further tax liability arose in India on the advertisement revenue. Prior tax treatment in earlier years did not prevent the assessee from disputing Indian taxability for the relevant year. en-us Tue, 13 Apr 2010 00:00:00 +0530 Mon, 13 Aug 2012 12:24:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122366 A foreign telecasting company's advertisement revenue was examined under section 9(1)(i) of the Income-tax Act and article 7(1) of the applicable treaty to determine the extent of Indian tax attribution. The Indian entity performed only marketing services for airtime and was paid arm's length remuneration. On that basis, the profit attributable to the Indian activity was treated as exhausted by the arm's length service fee, so no further tax liability arose in India on the advertisement revenue. Prior tax treatment in earlier years did not prevent the assessee from disputing Indian taxability for the relevant year. Case-Laws Income Tax Tue, 13 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122366