By Mariya Paliwala - On January 31, 2021 4:49 pm The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that the dependent agent permanent establishment (DAPE) is wholly tax-neutral if the Agent paid remuneration on Arm’s Length Price (ALP). The assessee, Asia Today Limited is a foreign telecasting company incorporated in Mauritius and having a tax residency certificate of 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.