Landmark order from ITAT

By Vijay Kumar

Sony Entertainment Television was set up to source advertising for AXN - a channel owned by Singapore-based SET Satellite. The Singapore company, SET Satellite, didn't pay any tax on advertising revenue from India as it was carrying on its activities through a commission agent.

The ITAT held, "whether one carries on the business directly or through a dependent agent, the profit attributable to such business continues to be taxable in the source country." What about the Ruling of the Advance Ruling Authority? That apparently is not binding on the Tribunal.

This judgement bound to have serious ramifications for the MNCs in India, is brought to you by TIOL today.

See 'Breaking News'