https://www.taxtmi.com/caselaws?id=433205 The Tribunal allowed Ground No. 7 of the appeal in favor of the appellant, dismissing other grounds. It upheld the appellant's position that Warner Bros. Pictures (India) Pvt. Ltd. is not a Dependent Agent Permanent Establishment (DAPE), leading to the conclusion that the royalty income is not taxable in India. The Tribunal emphasized the absence of a Permanent Establishment in India for the appellant, consistent with previous rulings, resulting in the appellant's appeal being allowed pro-tanto. en-us Fri, 02 Dec 2022 00:00:00 +0530 Mon, 23 Jan 2023 18:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433205 The Tribunal allowed Ground No. 7 of the appeal in favor of the appellant, dismissing other grounds. It upheld the appellant's position that Warner Bros. Pictures (India) Pvt. Ltd. is not a Dependent Agent Permanent Establishment (DAPE), leading to the conclusion that the royalty income is not taxable in India. The Tribunal emphasized the absence of a Permanent Establishment in India for the appellant, consistent with previous rulings, resulting in the appellant's appeal being allowed pro-tanto. Case-Laws Income Tax Fri, 02 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433205