https://www.taxtmi.com/caselaws?id=219355 Royalty received under a film distribution arrangement was held not taxable in India as business income where the non-resident had no permanent establishment in India. The Tribunal noted that the Indian company acted as an independent entity under the distribution arrangement, so the agency permanent establishment provisions did not apply. In the absence of a permanent establishment, the income could not be taxed in India merely on the basis of business connection. The ruling confirms that non-resident business profits are taxable in India only to the extent attributable to a permanent establishment. en-us Wed, 10 Oct 2012 00:00:00 +0530 Tue, 24 Jan 2023 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219355 Royalty received under a film distribution arrangement was held not taxable in India as business income where the non-resident had no permanent establishment in India. The Tribunal noted that the Indian company acted as an independent entity under the distribution arrangement, so the agency permanent establishment provisions did not apply. In the absence of a permanent establishment, the income could not be taxed in India merely on the basis of business connection. The ruling confirms that non-resident business profits are taxable in India only to the extent attributable to a permanent establishment. Case-Laws Income Tax Wed, 10 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219355