https://www.taxtmi.com/caselaws?id=151772 Under the India-Singapore DTAA, payment of arm's length remuneration to a dependent agent does not by itself exhaust the profits attributable to a dependent agent permanent establishment; profits must still be attributed separately to the foreign enterprise on a functional and factual basis under article 7. On that reasoning, exclusion of AXN advertisement revenue from Indian taxation, being based on the same premise, was unsustainable. The article also notes that interest under sections 234B and 234C was treated as not chargeable where tax was deductible at source, following coordinate bench and Special Bench decisions, and that only limited issues were remanded for fresh consideration by the first appellate authority. en-us Fri, 20 Apr 2007 00:00:00 +0530 Thu, 25 Jan 2024 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151772 Under the India-Singapore DTAA, payment of arm's length remuneration to a dependent agent does not by itself exhaust the profits attributable to a dependent agent permanent establishment; profits must still be attributed separately to the foreign enterprise on a functional and factual basis under article 7. On that reasoning, exclusion of AXN advertisement revenue from Indian taxation, being based on the same premise, was unsustainable. The article also notes that interest under sections 234B and 234C was treated as not chargeable where tax was deductible at source, following coordinate bench and Special Bench decisions, and that only limited issues were remanded for fresh consideration by the first appellate authority. Case-Laws Income Tax Fri, 20 Apr 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151772