https://www.taxtmi.com/caselaws?id=306360 Receipts for distribution and exhibition rights in cinematographic films were held to fall within the statutory exclusion from royalty under section 9(1)(vi), read with Explanation 2(v), of the Income-tax Act, so they were not taxable in India as royalty. The Tribunal also followed its earlier finding that the Indian distributor acted independently and did not constitute a dependent agent permanent establishment of the non-resident, so no business profits could be taxed in India in the absence of a PE. The same treaty position had been accepted for earlier years, and the revenue's appeal failed. en-us Thu, 27 Oct 2016 00:00:00 +0530 Tue, 24 Jan 2023 19:59:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306360 Receipts for distribution and exhibition rights in cinematographic films were held to fall within the statutory exclusion from royalty under section 9(1)(vi), read with Explanation 2(v), of the Income-tax Act, so they were not taxable in India as royalty. The Tribunal also followed its earlier finding that the Indian distributor acted independently and did not constitute a dependent agent permanent establishment of the non-resident, so no business profits could be taxed in India in the absence of a PE. The same treaty position had been accepted for earlier years, and the revenue's appeal failed. Case-Laws Income Tax Thu, 27 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306360