« Top Headlines » Open DEMAT Account in 24 hrs  Delhi HC Rules GST Registration Cannot Be Cancelled Retrospectively Without a Clear Show Cause Notice (SCN)  Belated income tax return AY 2026-27: How to file, late filing charges and what you may lose  Major Financial Changes from August 1, 2026: ITR Deadline, RBI MPC Meeting, Tatkal Ticket Rules & More  Government proposes to ease tax relief conditions for offshore funds  TallyPrime Connected Banking: Automating Banking and Accounting  ITR Filing Deadline 2026: Is July 31 the Last Date to File Your Income Tax Return? Latest Official Update  ITR filing deadline nears: How to file income tax return online on e-filing portal - quick 15-step guide  Will the ITR Filing Deadline Be Extended Beyond July 31 for FY 2025-26? Here's the Latest Update for Taxpayers  Income Tax Refund Delayed for AY 2026-27? 5 Common Reasons Your Refund May Be Stuck and How to Fix It  ITR Filing 2026: FM Nirmala Sitharaman Asks Tax Officials to Let Honest Taxpayers Correct Genuine Mistakes  Will Your FCNR Deposit Stay Tax-Free After Returning to India? Tax Rules Explained for NRIs «  SC defers hearing in Vicco Labs' matter... Luxembourg keen on DTAA with India... » SET can be taxed independently: ITAT April, 24th 2007 The Mumbai income-tax tribunal has stated foreign companies could be taxed independently even if their dependent agents are paid on an arms length basis.    The order has been passed in case of Sony Entertainment Television (SET) based in Singapore whose dependent agent is Sony India. SET- Singapore had earlier obtained a relief from the income-tax commissioner (appeals) for not being taxed in India, citing the advance ruling of Morgan Stanley.    In case of Morgan Stanley, the advance ruling authority has stated that if the dependent agent is paid at an arms length in India, the foreign company (Morgan Stanley parent) could not be taxed in India.    The order assumes significance since it will be applicable to all foreign companies which are operating in India on dependent agent basis. The assessment pertains to 2002-03 and the department has raised a demand of over Rs 100 crore.    A dependent agent is one who is legally and economically dependent on the principal (foreign company) and is authorised to negotiate and secure contracts on behalf of the foreign company.    The tribunal has held that the taxation of foreign company could be done since the permanent establishment of the foreign company and dependent agents are two different entities.    In this case, the authorities could tax the permanent establishment of the foreign company independently of the dependent agent.    The PE and the dependent agent are the same entities but the dependent agent is taxed as an Indian entity and the PE becomes the basis on which the foreign company is taxed on its Indian earnings.