Tax liability of company who have no PE in India and remunerate its Indian Agent on arm’s length basis

ORDER This is assesses’s appeal for the assessment year 2000- 01 against the Id. CIT(A)’s order dated 27.1.2006 confirming the AO’s action in holding that the assessee had a business connection in India u/s 9 of the Income Tax Act and that M/s. BBC Worldwide (India) Pvt. Limited (“BWIPL”, for short) was the assessee’s permanent establishment in India. 2. The brief facts are that the assessee company was incorporated under the laws of England and Wales. It is a part of the BBC Group. During the year under consideration, it was operating as an international co...