https://www.taxtmi.com/caselaws?id=259403 The Tribunal held that B4U India was not a dependent agent of the assessee under the Indo-Mauritius Treaty. Even if considered a dependent agent, B4U was remunerated at arm's length, precluding further profit attribution. The assessee was not required to deduct tax under section 195 for transponder charges, as the payments were not taxable in India. The Tribunal concluded that the amount in question was not liable to tax in India as royalty consideration under section 9 of the IT Act. The Tribunal's decision was upheld, dismissing the Revenue's appeals without costs. en-us Wed, 29 Apr 2015 00:00:00 +0530 Tue, 11 Aug 2015 16:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259403 The Tribunal held that B4U India was not a dependent agent of the assessee under the Indo-Mauritius Treaty. Even if considered a dependent agent, B4U was remunerated at arm's length, precluding further profit attribution. The assessee was not required to deduct tax under section 195 for transponder charges, as the payments were not taxable in India. The Tribunal concluded that the amount in question was not liable to tax in India as royalty consideration under section 9 of the IT Act. The Tribunal's decision was upheld, dismissing the Revenue's appeals without costs. Case-Laws Income Tax Wed, 29 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259403