In absence of PE Royalty Income of Warner Bros., USA arising outside India cannot be taxed

Warner Bros. Distributing Inc Vs ACIT (ITAT Mumbai)

The assessee is a tax resident of USA. The assessee is engaged in export of films from USA, produced either by its group studios or produced by third parties. The assessee has entered into an agreement dated 01/04/2009 with Warner Bros. Pictures (India) Pvt. Ltd. granting exclusive rights of distribution of cinematographic films on payment of royalty in terms of the above referred Agreement. During the period, relevant to assessment year under appeal, the assessee received Rs.39,19,73,663/- in the natu

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