https://www.taxtmi.com/caselaws?id=432656 Distribution rights for broadcast channels, without transfer of copyright in the underlying content, constitute a commercial right rather than royalty under the India-Mauritius tax treaty or domestic royalty provisions. A fixed place permanent establishment requires premises in India to be at the foreign enterprise's disposal, while a dependent agent permanent establishment requires authority to conclude contracts or conduct beyond ordinary independent business. Neither condition was established for the Indian distributor. Where the Indian entity receives arm's-length remuneration, no further profits are attributable even if a permanent establishment is assumed. Interest for non-resident treaty-based taxability was treated as chargeable under the applicable precedent. en-us Mon, 21 Nov 2022 00:00:00 +0530 Thu, 06 Aug 2026 17:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432656 Distribution rights for broadcast channels, without transfer of copyright in the underlying content, constitute a commercial right rather than royalty under the India-Mauritius tax treaty or domestic royalty provisions. A fixed place permanent establishment requires premises in India to be at the foreign enterprise's disposal, while a dependent agent permanent establishment requires authority to conclude contracts or conduct beyond ordinary independent business. Neither condition was established for the Indian distributor. Where the Indian entity receives arm's-length remuneration, no further profits are attributable even if a permanent establishment is assumed. Interest for non-resident treaty-based taxability was treated as chargeable under the applicable precedent. Case-Laws Income Tax Mon, 21 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432656