https://www.taxtmi.com/caselaws?id=397375 Consultation and approval rights limited to passive monitoring did not establish control sufficient for Associated Enterprise status, so remittances to the foreign film producer were not treated as attracting withholding on that basis. The foreign entity was described as an independent service provider with its own financing and responsibility to produce and deliver the film on a lump-sum basis. The Indian service provider was also held not to be a Permanent Establishment or dependent agent, because its limited production services and small receipts relative to turnover did not show dependent business activity. As no income was attributable to a Permanent Establishment in India, the withholding premise under section 195 and default exposure under section 201 failed. en-us Tue, 11 Aug 2020 00:00:00 +0530 Mon, 17 Aug 2020 11:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397375 Consultation and approval rights limited to passive monitoring did not establish control sufficient for Associated Enterprise status, so remittances to the foreign film producer were not treated as attracting withholding on that basis. The foreign entity was described as an independent service provider with its own financing and responsibility to produce and deliver the film on a lump-sum basis. The Indian service provider was also held not to be a Permanent Establishment or dependent agent, because its limited production services and small receipts relative to turnover did not show dependent business activity. As no income was attributable to a Permanent Establishment in India, the withholding premise under section 195 and default exposure under section 201 failed. Case-Laws Income Tax Tue, 11 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397375