https://www.taxtmi.com/caselaws?id=306381 Royalty-like receipts from foreign cinematographic film distribution agreements were held not taxable in India as business income where the same contractual arrangement had already been accepted in the assessee's favour in earlier years. The Tribunal noted that, absent any distinguishing facts, non-resident income can be taxed only to the extent attributable to a permanent establishment, and no attributable Indian profits were shown from a dependent agent permanent establishment. The addition was therefore deleted. en-us Tue, 30 Nov 2021 00:00:00 +0530 Tue, 24 Jan 2023 21:23:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306381 Royalty-like receipts from foreign cinematographic film distribution agreements were held not taxable in India as business income where the same contractual arrangement had already been accepted in the assessee's favour in earlier years. The Tribunal noted that, absent any distinguishing facts, non-resident income can be taxed only to the extent attributable to a permanent establishment, and no attributable Indian profits were shown from a dependent agent permanent establishment. The addition was therefore deleted. Case-Laws Income Tax Tue, 30 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306381