Held that Indian entity was remunerated at arm’s length price by assessee, which was also accepted by TPO of both entities, assessee had no business connection in India in terms of section 9(1) and had no PE and, thus, no further attribution of profits was to be made. (AY. 2012-13)
ESPN Star Sports Mauritius SNC et Compagnie v. DCIT (2022) 193 ITD 275 (Delhi)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Support service-Outsourcing of work to India would not give rise to a fixed place PE-DTAA-India-Mauritius. [Art. 5]