The Mumbai Bench of the Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 20 April 2007 in the cases of Deputy Director of Income Tax v. SET Satellite (Singapore) Pte. Ltd. (ITA No. 535/Mum/04) and SET Satellite (Singapore) Pte. Ltd. v. Deputy Director of Income Tax (ITA No. 205/Mum/04) on whether the payment of an arm's length remuneration to an agent results in that agent not being a permanent establishment and extinguishes any further tax liability the foreign principal has in India in connection the connected operations in India. (a) Facts. The Taxpayer (SET Satellite (Singapore) Pte. Ltd.,...