No Tax on Income of company registered in Isle of Man received as principal from its agent in India

ACIT Vs Star Cruise Management Ltd (ITAT Mumbai) ITAT Mumbai held that services provided by Indian Company to company registered in Isle of Man (i.e. non-resident company) under Canvasser Agent Agreement, on principal-to-principal basis not taxable in India. Facts- The Assessee [i.e. Star Cruise Management Ltd.], a company registered in Isle of Man, was engaged in the canvassing business of travel and tour related services. The Assessee had entered into Canvasser Agent Agreement, dated 01/04/2005, with Star Cruises (India) Travel Services Pvt. Ltd., (the Indian Company) for canvassing the crui...