https://www.taxtmi.com/caselaws?id=264125 A non-resident enterprise with an Indian dependent agent was not subjected to further Indian tax on advertisement and distribution revenues where the agent had been remunerated at arm's length for the relevant functions and risks, leaving no additional profit to attribute to the foreign enterprise. Distribution receipts were treated consistently as business income, not royalty, on identical facts. Interest under section 234B was stated to be not leviable in the treaty-based non-resident context, while interest under section 244A was addressed under the treaty framework applied in Clough Engineering Ltd. Tax deducted at source credit was to be granted, subject to verification of records. en-us Fri, 28 Aug 2015 00:00:00 +0530 Sat, 18 Jun 2022 11:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264125 A non-resident enterprise with an Indian dependent agent was not subjected to further Indian tax on advertisement and distribution revenues where the agent had been remunerated at arm's length for the relevant functions and risks, leaving no additional profit to attribute to the foreign enterprise. Distribution receipts were treated consistently as business income, not royalty, on identical facts. Interest under section 234B was stated to be not leviable in the treaty-based non-resident context, while interest under section 244A was addressed under the treaty framework applied in Clough Engineering Ltd. Tax deducted at source credit was to be granted, subject to verification of records. Case-Laws Income Tax Fri, 28 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264125