https://www.taxtmi.com/caselaws?id=151772 Dependent agent permanent establishment profit attribution under article 7 of the India-Singapore DTAA is distinct from the arm's length remuneration paid to the dependent agent. Profits attributable to the foreign enterprise's permanent establishment must be determined separately on a functional and factual basis; the agent's commission does not by itself exhaust Indian tax liability. On that basis, exclusion of AXN channel advertisement revenue from Indian taxation was unsustainable where it depended solely on the arm's length remuneration proposition. Interest for advance-tax defaults was not chargeable where tax was deductible at source, and limited issues required fresh adjudication 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 Dependent agent permanent establishment profit attribution under article 7 of the India-Singapore DTAA is distinct from the arm's length remuneration paid to the dependent agent. Profits attributable to the foreign enterprise's permanent establishment must be determined separately on a functional and factual basis; the agent's commission does not by itself exhaust Indian tax liability. On that basis, exclusion of AXN channel advertisement revenue from Indian taxation was unsustainable where it depended solely on the arm's length remuneration proposition. Interest for advance-tax defaults was not chargeable where tax was deductible at source, and limited issues required fresh adjudication by the first appellate authority. Case-Laws Income Tax Fri, 20 Apr 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151772