Cricket marketing income in India exempt from tax under DTAA with Mauritius; no permanent establishment in India.

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....Income accrued or deemed to accrue in India - marketing and advertising rights that have been granted under the MAA [Marketing and Advertising Agreement'] - rights under MAA - source of income was the game of cricket played in India - In the absence of any permanent establishment of the payee in India, is not chargeable to tax in India. Therefore, the payment made by the Applicant to IML for grant of commercial rights under MAA is not taxable in India as per the provisions of the DTAA between India and Mauritius. - AAR....