https://www.taxtmi.com/caselaws?id=306363 Receipts from distribution rights of cinematographic films were held not taxable in India as royalty under the domestic law or the India-USA DTAA. The Tribunal followed its consistent view in the assessee's earlier years, found no distinguishing facts for the year under appeal, and noted that the agreement concerned film distribution rather than royalty. It also held that, in the absence of a permanent establishment in India, business profits could not be taxed merely on the basis of business connection or the character of the receipts. The additions were deleted in favour of the assessee. en-us Mon, 14 Oct 2019 00:00:00 +0530 Tue, 24 Jan 2023 19:59:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306363 Receipts from distribution rights of cinematographic films were held not taxable in India as royalty under the domestic law or the India-USA DTAA. The Tribunal followed its consistent view in the assessee's earlier years, found no distinguishing facts for the year under appeal, and noted that the agreement concerned film distribution rather than royalty. It also held that, in the absence of a permanent establishment in India, business profits could not be taxed merely on the basis of business connection or the character of the receipts. The additions were deleted in favour of the assessee. Case-Laws Income Tax Mon, 14 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306363