https://www.taxtmi.com/caselaws?id=307474 Where an Indian agent is remunerated at arm's length, no dependent agent PE is constituted on the facts described and no further profits are attributable in India from advertisement revenue; the attribution addition was deleted. Payments for programming rights and transponder facilities were not treated as taxable royalty on the relevant dates, so no tax was deductible at source under section 195 and disallowance under section 40(a)(i) could not stand; the disallowance was deleted. en-us Fri, 20 Jul 2018 00:00:00 +0530 Sun, 16 Apr 2023 17:07:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307474 Where an Indian agent is remunerated at arm's length, no dependent agent PE is constituted on the facts described and no further profits are attributable in India from advertisement revenue; the attribution addition was deleted. Payments for programming rights and transponder facilities were not treated as taxable royalty on the relevant dates, so no tax was deductible at source under section 195 and disallowance under section 40(a)(i) could not stand; the disallowance was deleted. Case-Laws Income Tax Fri, 20 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307474