https://www.taxtmi.com/caselaws?id=306103 Where an Indian agent was remunerated at arm's length and transfer pricing was accepted without adjustment, no further profit attribution to the non-resident principal was warranted, and the advertisement revenue addition was deleted. Distribution receipts were treated as consideration for limited channel distribution rights, not as royalty or fees for included services, because no copyright or right to exploit copyrighted work was transferred under the India-USA DTAA and the Act. TDS credit and additional TDS credit were left to verification on supporting records, section 234D interest was consequential, and penalty proceedings under sections 271(1)(c), 271A and 271B were held premature. en-us Mon, 12 Jul 2021 00:00:00 +0530 Tue, 18 Apr 2023 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306103 Where an Indian agent was remunerated at arm's length and transfer pricing was accepted without adjustment, no further profit attribution to the non-resident principal was warranted, and the advertisement revenue addition was deleted. Distribution receipts were treated as consideration for limited channel distribution rights, not as royalty or fees for included services, because no copyright or right to exploit copyrighted work was transferred under the India-USA DTAA and the Act. TDS credit and additional TDS credit were left to verification on supporting records, section 234D interest was consequential, and penalty proceedings under sections 271(1)(c), 271A and 271B were held premature. Case-Laws Income Tax Mon, 12 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306103