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India-USA Tax Treaty: 10% of Ad and Subscription Revenue Taxable for Companies with Indian Permanent Establishments.

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....Taxability of advertisement revenue & subscription revenue - Tax Treaty between India and USA - Appellant has a PE in India, both Advertisement and Subscription revenues constitute business income of the Appellant in India and that 10% of the Advertisement and Subscription revenues be treated as taxable income of the appellant in India. - AT....

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India-USA Tax Treaty: 10% of Ad and Subscription Revenue Taxable for Companies with Indian Permanent Establishments.