https://www.taxtmi.com/caselaws?id=306335 Amounts received under a film distribution agreement were not taxable in India as business profits because the non-resident had no permanent establishment in India. The Tribunal followed its earlier year's view that the Indian company acted independently and therefore did not constitute an agency permanent establishment. It applied the principle that, even where a business connection is alleged, Indian taxation of a non-resident's business income is limited to profits attributable to a permanent establishment. On the facts found, no such permanent establishment existed, so the distribution receipts could not be brought to tax in India as business income. en-us Fri, 22 Feb 2013 00:00:00 +0530 Fri, 10 Mar 2023 16:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306335 Amounts received under a film distribution agreement were not taxable in India as business profits because the non-resident had no permanent establishment in India. The Tribunal followed its earlier year's view that the Indian company acted independently and therefore did not constitute an agency permanent establishment. It applied the principle that, even where a business connection is alleged, Indian taxation of a non-resident's business income is limited to profits attributable to a permanent establishment. On the facts found, no such permanent establishment existed, so the distribution receipts could not be brought to tax in India as business income. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306335