https://www.taxtmi.com/caselaws?id=307486 The Tribunal followed its earlier years' view that Taj India did not constitute an agency permanent establishment in India under the India-Mauritius DTAA, and that no further profit could be attributed to the foreign enterprise where the dependent agent was already remunerated at arm's length. It also followed prior orders holding that programming cost, transponder charges and up-linking charges were not liable to disallowance under section 40(a)(i) for non-deduction of tax at source. Once the permanent establishment and attribution findings were made, the transfer pricing adjustment ground was treated as infructuous. en-us Wed, 22 May 2019 00:00:00 +0530 Mon, 17 Apr 2023 21:15:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307486 The Tribunal followed its earlier years' view that Taj India did not constitute an agency permanent establishment in India under the India-Mauritius DTAA, and that no further profit could be attributed to the foreign enterprise where the dependent agent was already remunerated at arm's length. It also followed prior orders holding that programming cost, transponder charges and up-linking charges were not liable to disallowance under section 40(a)(i) for non-deduction of tax at source. Once the permanent establishment and attribution findings were made, the transfer pricing adjustment ground was treated as infructuous. Case-Laws Income Tax Wed, 22 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307486