https://www.taxtmi.com/caselaws?id=402533 Where a non-resident's Indian representative is remunerated at arm's length, no further profits are attributable to the foreign enterprise merely because the representative is alleged to be a permanent establishment; the agent's dependent-agent status was also not established on the facts. A limited right to distribute television channels was treated as a commercial distribution right, not a transfer of copyright or any right to exploit copyrighted works, so the receipts were not royalty or fees for included services under the India-US treaty or domestic law. Interest under section 234B was also held not leviable on a non-resident where the income was subject to tax deduction at source by the payer. en-us Wed, 30 Dec 2020 00:00:00 +0530 Tue, 05 Jan 2021 11:13:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402533 Where a non-resident's Indian representative is remunerated at arm's length, no further profits are attributable to the foreign enterprise merely because the representative is alleged to be a permanent establishment; the agent's dependent-agent status was also not established on the facts. A limited right to distribute television channels was treated as a commercial distribution right, not a transfer of copyright or any right to exploit copyrighted works, so the receipts were not royalty or fees for included services under the India-US treaty or domestic law. Interest under section 234B was also held not leviable on a non-resident where the income was subject to tax deduction at source by the payer. Case-Laws Income Tax Wed, 30 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402533