« Top Headlines » Open DEMAT Account in 24 hrs  Mock Test Papers Series - I & II for Students appearing in CA Foundation January 2027 Examination.  Income Tax Rules 2026: CBDT Introduces Revised Form 161 for Penalty Waiver, Clarifies Misreporting Categories and Taxpayer Relief  ITR Filing and Income Tax Audit Deadline Extended: 5 Critical Things Taxpayers Must Know  Filing Belated ITR for AY 2026-27? Know Which Losses You Can Carry Forward and Which You May Lose  CBDT Extends Tax Audit Report Deadline to October 21, ITR Filing Last Date to November 21 for AY 2026-27  CBDT Extends AY 2026-27 ITR Filing Deadline for Tax-Audit Cases: New Dates and Key Compliance Details  Foreign Assets Missing From Your ITR? Income Tax Department Opens One-Time Disclosure Window  Tax Audit Deadline September 30: Why AIS, TDS and GST Figures May Not Match Your ITR and What Taxpayers Should Do  Tax audit deadline September 30: Common mistakes taxpayers should avoid  Your ITR says ‘verified’, but the refund hasn’t arrived? 5 reasons why your money could be stuck  Missed the ITR Deadline but TDS Refund Is Due? Here’s How You Can Still Claim Your Money «  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.