https://www.taxtmi.com/caselaws?id=344775 The transaction structure was treated as successive purchase and sale of advertisement space on a principal-to-principal basis, with remittance and recovery reflecting independent commercial dealings. Common directorship alone was held insufficient to establish an agency relationship or dependent agent permanent establishment in India under Article 5 of the India-USA tax treaty. The authorities' concurrent finding that the dealings were at arm's length was not shown to be erroneous, and no substantial question of law arose for interference under section 9(2). The department's challenge was therefore rejected. en-us Wed, 07 Jun 2017 00:00:00 +0530 Tue, 27 Jun 2017 15:53:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344775 The transaction structure was treated as successive purchase and sale of advertisement space on a principal-to-principal basis, with remittance and recovery reflecting independent commercial dealings. Common directorship alone was held insufficient to establish an agency relationship or dependent agent permanent establishment in India under Article 5 of the India-USA tax treaty. The authorities' concurrent finding that the dealings were at arm's length was not shown to be erroneous, and no substantial question of law arose for interference under section 9(2). The department's challenge was therefore rejected. Case-Laws Income Tax Wed, 07 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344775