https://www.taxtmi.com/caselaws?id=6577 A resident concessionaire handling advertisements for a non-resident created a business connection in India under section 9(1)(i) read with Explanation 2, so the non-resident's income from those activities was deemed to accrue or arise in India. However, the same resident was not treated as a permanent establishment under article 5 of the treaty because it had other clients and its work for the non-resident was not wholly or almost wholly devoted to that business. By virtue of section 90, the treaty position prevailed, so the non-resident's business profits were not taxable in India under article 7. en-us Mon, 07 Feb 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6577 A resident concessionaire handling advertisements for a non-resident created a business connection in India under section 9(1)(i) read with Explanation 2, so the non-resident's income from those activities was deemed to accrue or arise in India. However, the same resident was not treated as a permanent establishment under article 5 of the treaty because it had other clients and its work for the non-resident was not wholly or almost wholly devoted to that business. By virtue of section 90, the treaty position prevailed, so the non-resident's business profits were not taxable in India under article 7. Case-Laws Income Tax Mon, 07 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6577