Existence of a DAPE is wholly tax neutral

ADIT Vs Asia Today Limited (ITAT Mumbai) Facts- Main issue involved is the assessee claim that it is a foreign telecasting company incorporated in Mauritius and having a tax residency certificate of the Mauritius. It sells advertising time and collects subscription revenues through its Indian affiliates Zee Telefilms Limited and El Zee, but its claim was that since it does not have any permanent establishment in India, no part of its income was taxable in India. whereas, AO did not accept the claim. He was of the view that its Indian agent constitute virtual projection of the foreign company, ...