B4U had no Indian PE as it was extending time slots for ads through agents not having authority to c

IT/ILT: Assessee, a Mauritius based company was engaged in business of telecasting TV channels - Assessing Officer held that income of assessee from giving time slots to advertisers through its agents was taxable in India as said agents constituted its PE- within meaning of article 5 of India - Mauritius DTAA - It was noted that assessee carried out entire activities from Mauritius and all contracts were concluded in Mauritius - It was also undisputed that only activity which was carried out in