https://www.taxtmi.com/caselaws?id=780109 Transfer pricing and treaty characterisation issues concerning a foreign film distributor's Indian arrangements were analysed under the India-US tax treaty and section 9(1)(vi). No further profit attribution was permitted where the India-related transaction had been accepted at arm's length and the alleged dependent agent permanent establishment was not shown to justify additional profits. Distribution receipts from cinematographic films were treated as outside the royalty charge because the statutory and treaty exclusions applied. Interest on income-tax refund was also computed under the treaty interest article at 15%, rather than the domestic rate, on the basis that the relevant income was not taxed as effectively connected with a permanent establishment. en-us Mon, 13 Oct 2025 00:00:00 +0530 Fri, 17 Oct 2025 12:52:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780109 Transfer pricing and treaty characterisation issues concerning a foreign film distributor's Indian arrangements were analysed under the India-US tax treaty and section 9(1)(vi). No further profit attribution was permitted where the India-related transaction had been accepted at arm's length and the alleged dependent agent permanent establishment was not shown to justify additional profits. Distribution receipts from cinematographic films were treated as outside the royalty charge because the statutory and treaty exclusions applied. Interest on income-tax refund was also computed under the treaty interest article at 15%, rather than the domestic rate, on the basis that the relevant income was not taxed as effectively connected with a permanent establishment. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780109