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Indian decision on the attribution of profits to dependent agent permanent establishment

|Treaty Development|India-Singapore
India-Singapore

The Mumbai Bench of the Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 20 April 2007 in the cases of Deputy Director of Income Tax v. SET Satellite (Singapore) Pte. Ltd. (ITA No. 535/Mum/04) and SET Satellite (Singapore) Pte. Ltd. v. Deputy Director of Income Tax (ITA No. 205/Mum/04) on whether the payment of an arm's length remuneration to an agent results in that agent not being a permanent establishment and extinguishes any further tax liabilit…

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