A company working independently on principal-to-principal basis cannot be called AE

Next Gen Films Private Ltd. Vs ITO (Int. Tax-TDS) (ITAT Mumbai) Regarding commissioning agreement entered into by the assessee (Next Gen Films Private Ltd.) with M/s DBPL, at para 2.12, we reached a conclusion that the contract between the assessee and M/s DBPL (M/s Desi Boyz Production Ltd. )  was primarily on principal-to- principal basis. The entire responsibility to produce the film was on M/s DBPL against certain lump-sum consideration. M/s DBPL was required to produce the film and ensure the delivery of the film as per given specifications. The film was to be fully synchronized as to di...