Advertisement and distribution revenue of Discovery Asia INC. taxable as per MAP

Discovery Networks Asia Pacific Pte Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially. Facts- Discovery Networks Asia Pacific Pte Ltd [DNAP] is a tax resident company of Singapore within the meaning of Article 4 of the India-Singapore Double Taxation Avoidance Agreement (‘the Treaty’). Discovery Communications India (DCIN) is a company incorporated in India and is engaged in ...