Income from Film Distribution Not Taxable in India Due to No Permanent Establishment Under Agency PE Provisions.

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....Royalty for exclusive rights of distribution of Cinematographic films – assessee has a business connection in India but does not have any P.E. in India. Since the Indian company who obtained the rights is acting independently, Agency PE provisions are not applicable to the assessee company. Thus, the incomes arising outside Indian Territories cannot be brought to tax .... - AT....