https://www.taxtmi.com/caselaws?id=172911 Under Article 12(7) of the India-Singapore DTAA, royalty is deemed to arise in India only where the payer is resident in India, or where a non-resident payer's Indian permanent establishment incurs and bears the liability with an economic nexus to the payment. Mere existence of an Indian permanent establishment is not enough. On the stated facts, the broadcasting-rights royalty was linked to Singapore head-office operations, not to any Indian permanent establishment, so the payment was not chargeable to tax in India and no tax deduction obligation arose. en-us Fri, 25 Jun 2010 00:00:00 +0530 Wed, 18 Dec 2024 15:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=172911 Under Article 12(7) of the India-Singapore DTAA, royalty is deemed to arise in India only where the payer is resident in India, or where a non-resident payer's Indian permanent establishment incurs and bears the liability with an economic nexus to the payment. Mere existence of an Indian permanent establishment is not enough. On the stated facts, the broadcasting-rights royalty was linked to Singapore head-office operations, not to any Indian permanent establishment, so the payment was not chargeable to tax in India and no tax deduction obligation arose. Case-Laws Income Tax Fri, 25 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=172911