https://www.taxtmi.com/caselaws?id=459614 Delhi HC dismissed appeals regarding permanent establishment (PE) and royalty issues. Court held appellant failed to prove fixed place PE and found no dependent agent PE under India-Mauritius DTAA as Indian entities lacked authority to conclude contracts for the Mauritius entity. Indian entities operated independently, bearing distribution costs without connection to Mauritius entity's contracts. Regarding royalty, payments didn't constitute consideration for copyright use as no copyright transfer occurred, only broadcasting rights were involved. Court distinguished broadcasting rights from copyright per statutory provisions and SC precedents. en-us Tue, 13 Feb 2024 00:00:00 +0530 Thu, 19 Dec 2024 18:58:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459614 Delhi HC dismissed appeals regarding permanent establishment (PE) and royalty issues. Court held appellant failed to prove fixed place PE and found no dependent agent PE under India-Mauritius DTAA as Indian entities lacked authority to conclude contracts for the Mauritius entity. Indian entities operated independently, bearing distribution costs without connection to Mauritius entity's contracts. Regarding royalty, payments didn't constitute consideration for copyright use as no copyright transfer occurred, only broadcasting rights were involved. Court distinguished broadcasting rights from copyright per statutory provisions and SC precedents. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459614