Held that as long as an agent is paid an arm’s length remuneration for services rendered, nothing survived for taxation in hands of dependent agency permanent establishment, and since existence of a dependent agency permanent establishment was wholly tax neutral income of applicant could not be held to be taxable in India. (AY. 2006-07, 2007-08)
Asia TV (UK) Ltd. v. DIT (2021) 188 ITD 676 (Mum.)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Commission to Indian agent-Arm’s length remuneration-Income cannot be taxed in India-DTAA-India-UK. [S. 92C, Art. 5(4), 5(5), 7]