Income of non-resident for production of television signals for broadcasting of cricket matches in India taxable as fees for technical services on gross basis

Nimbus Sport International Pte. Ltd. Vs DDIT (ITAT Delhi) -Coming to the issue about the advertisement revenue received by the assessee in Singapore for matches played abroad, it has not been disputed that the matches in question for which advertisements were given by the Indian company were all played in foreign countries. The assessee does not have a PE in India. In this eventuality, the revenue collected by it for the matches played overseas and telecast at overseas will not attract the theory of force of attraction for taxing them in India. The force of attraction cannot apply on an assum...