Assessee-partnership firm, incorporated under laws of Mauritius, was engaged in business of acquiring and allotting advertisement time (‘Airtime’) and programme sponsorship in connection with programming via non-standard television from Mauritius. It entered into an agreement with Indian entity which was engaged in business of acquiring airtime from assessee and allotting it to various Indian advertising agencies.  Assessing Officer held that said Indian entity constituted to be Dependent Agent Permanent Establishment (DAPE) of assessee as per Article 5(4) of India-Mauritus DTAA and attributed 30 per cent of gross revenue from India as profits to said Indian entity. Tribunal held that   since said Indian entity was remunerated at arm’s length price by assessee, which was also accepted by TPO of both entities, no further attribution of profits was to be made.  (AYs. 2009-10, 2011-12)