India's Distribution Revenue Taxed as Business Income, Not Royalty; MAP Agreement Continues to Apply Per Tax Authorities.

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....Income accrue in India - PE in India - nature of income - the distribution revenue earned by the appellant-assessee cannot be taxed as royalty albeit as a business income. Since, assessee has already offered income as business income in terms of the MAP, therefore, the income as declared by the assessee in accordance with the MAP and accepted by the Department in the earlier years has to be accepted. - AT....