https://www.taxtmi.com/caselaws?id=433205 Where the material facts were unchanged from earlier years and the Indian company acted independently, no dependent agent permanent establishment arose in India. The Tribunal followed its consistent view in the assessee's own case, found no contrary decision, and held that the royalty income could not be taxed in India on the basis of agency PE attribution. The foreign enterprise therefore remained outside Indian taxability on this ground. 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 Where the material facts were unchanged from earlier years and the Indian company acted independently, no dependent agent permanent establishment arose in India. The Tribunal followed its consistent view in the assessee's own case, found no contrary decision, and held that the royalty income could not be taxed in India on the basis of agency PE attribution. The foreign enterprise therefore remained outside Indian taxability on this ground. Case-Laws Income Tax Fri, 02 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433205