https://www.taxtmi.com/caselaws?id=221788 The company, incorporated in the Cayman Islands and operating from Singapore, was found to have an agency Permanent Establishment (PE) in India through its agent, MTV India (P) Ltd., involved in advertising sales. The attribution of advertising revenue to the PE varied for different assessment years, with the Tribunal upholding 10% attribution based on CBDT Circular No. 742. Interest levied under Sections 234D and 234B was dismissed in favor of the assessee. The appeals for assessment years 2002-03 to 2005-06 were partly allowed for the assessee, while the Revenue's appeal for 2005-06 was partly allowed. en-us Tue, 31 Jan 2012 00:00:00 +0530 Sat, 30 Mar 2013 08:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221788 The company, incorporated in the Cayman Islands and operating from Singapore, was found to have an agency Permanent Establishment (PE) in India through its agent, MTV India (P) Ltd., involved in advertising sales. The attribution of advertising revenue to the PE varied for different assessment years, with the Tribunal upholding 10% attribution based on CBDT Circular No. 742. Interest levied under Sections 234D and 234B was dismissed in favor of the assessee. The appeals for assessment years 2002-03 to 2005-06 were partly allowed for the assessee, while the Revenue's appeal for 2005-06 was partly allowed. Case-Laws Income Tax Tue, 31 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221788