https://www.taxtmi.com/caselaws?id=432656 A right to distribute broadcast content, without transfer of copyright in the underlying work, is treated as a commercial distribution right and not royalty under the India-Mauritius tax treaty or section 9(1)(vi). The material also explains that a fixed place permanent establishment requires premises in India at the foreign enterprise's disposal, and a dependent agent permanent establishment requires authority to conclude contracts or comparable agency functions; on the facts discussed, neither existed. Where the Indian entity was remunerated at arm's length, no further profit attribution was warranted. The note further records that interest under section 234B remained chargeable on binding precedent. en-us Mon, 21 Nov 2022 00:00:00 +0530 Mon, 10 Jun 2024 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432656 A right to distribute broadcast content, without transfer of copyright in the underlying work, is treated as a commercial distribution right and not royalty under the India-Mauritius tax treaty or section 9(1)(vi). The material also explains that a fixed place permanent establishment requires premises in India at the foreign enterprise's disposal, and a dependent agent permanent establishment requires authority to conclude contracts or comparable agency functions; on the facts discussed, neither existed. Where the Indian entity was remunerated at arm's length, no further profit attribution was warranted. The note further records that interest under section 234B remained chargeable on binding precedent. Case-Laws Income Tax Mon, 21 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432656