https://www.taxtmi.com/caselaws?id=264125 The Tribunal upheld the CIT(A)'s decision that advertisement revenue is not taxable in India due to lack of Permanent Establishment. Distribution revenue was treated as business income, not 'royalty,' and not taxable in the absence of a PE. Interest u/s 234B was deleted, following precedent. Penalty u/s 271B was deemed inapplicable. The assessee's appeal on taxability of distribution revenue was dismissed as the issue was decided in their favor. Interest u/s 244A was not taxed under the India-Singapore Treaty. TDS credit was granted to the assessee. The Tribunal dismissed the revenue's appeal and allowed the assessee's appeals for AY 2005-06 and 2006-07. 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 The Tribunal upheld the CIT(A)'s decision that advertisement revenue is not taxable in India due to lack of Permanent Establishment. Distribution revenue was treated as business income, not 'royalty,' and not taxable in the absence of a PE. Interest u/s 234B was deleted, following precedent. Penalty u/s 271B was deemed inapplicable. The assessee's appeal on taxability of distribution revenue was dismissed as the issue was decided in their favor. Interest u/s 244A was not taxed under the India-Singapore Treaty. TDS credit was granted to the assessee. The Tribunal dismissed the revenue's appeal and allowed the assessee's appeals for AY 2005-06 and 2006-07. Case-Laws Income Tax Fri, 28 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264125