https://www.taxtmi.com/caselaws?id=212473 The Tribunal held that the assessee had no permanent establishment in India because the contractual activity, bid process, and agreement were carried out from Singapore, and the evidence did not show a fixed place at its disposal or a service PE beyond the treaty threshold. It also held that receipts from Prasar Bharti for producing live television signals were fees for technical services, as technical knowledge and know-how were made available, and therefore taxable at the treaty rate of 10% rather than 20%. Advertisement revenue received outside India was not taxable in India in the absence of a PE and attribution to India. Interest under sections 234B and 234C was not chargeable where the receipts were subject to TDS. en-us Fri, 30 Sep 2011 00:00:00 +0530 Fri, 22 Apr 2016 15:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212473 The Tribunal held that the assessee had no permanent establishment in India because the contractual activity, bid process, and agreement were carried out from Singapore, and the evidence did not show a fixed place at its disposal or a service PE beyond the treaty threshold. It also held that receipts from Prasar Bharti for producing live television signals were fees for technical services, as technical knowledge and know-how were made available, and therefore taxable at the treaty rate of 10% rather than 20%. Advertisement revenue received outside India was not taxable in India in the absence of a PE and attribution to India. Interest under sections 234B and 234C was not chargeable where the receipts were subject to TDS. Case-Laws Income Tax Fri, 30 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212473