Sum paid to foreign entity for advertisement in foreign journals wasn't taxable in absence of its PE in India

ITAT Delhi bench held that where assessee had made remittances to foreign countries related to rent for office accommodation, expenses incurred toward exhibitions outside India and advertisement in foreign journals towards display of its products, since foreign parties did not have their PE in India, said payments were not chargeable to tax in India. Income-tax Officer, Ward 1 (1) (2), International Taxation, New Delhi v. Brahmos Aerospace (P.) Ltd. [2016] 74 taxmann.com 191