Foreign artistes are chargeable to tax in India but their agents are not in the absence of PE- ITAT Mumbai

Court: ITAT, Mumbai

Citation: The Asst. Director of Income Tax (International Taxation) Vs. M/s. Wiz craft International Entertainment Pvt. Ltd.- (I.T.A.No. 3208/Mum/2003)

Brief: Commission paid to agents for services rendered outside India is not chargeable to tax in India and there is no obligation to deduct tax u/s 195. As Agent was not a performer, his income was not covered under Article 18 of the DTAA but was covered by Article 7 and a

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