Tax U/s. 195 not deductible on consideration for live broadcasting

Asst. DIT (Intl. Tax.) v. M/s.Neo Sports Broadcast Private Limited (ITAT mumbai) –  The relevant criteria is the carrying on of business operations in India by the non-resident and not the earning of income by any resident from the use of any product acquired from the non-resident. Where the non-resident only allows some resident to exploit certain right vested in it on commercial basis, it cannot be said that the non-resident has carried out any business activity in India. The act of the assessee earning revenues from India cannot lead to a business connection of Nimbus in India as t...