Agents not working exclusively for assessee and having no power to conclude contracts are not dependent agents

Brief of the case: The Hon’ble Bombay High Court in the case of B4U International Holdings held that the agents of the foreign company if not exclusively working for assessee and they are not decision makers with no power of concluding contracts and as such their activities being incidental in nature. Therefore, such agents cannot be treated as Dependent Agent Permanent Establishment (DAPE) of the assessee. Facts of the case: The assessee is a foreign company incorporated in Mauritius engaged in telecasting of TV channels. It earned income from selling time slot to advertising from India....