Tax on payment by Indian company to foreign celebrity for appearance outside India

Volkswagen Finance Pvt Ltd Vs ITO (ITAT Mumbai)

In this case ITAT held that we are of the considered view that the income embedded in payment to the international celebrity (Nicholas Cage), for participation in Dubai A8L launch event for promoting the business of the assessee in India, is taxable as arising from a ‘business connection’ and also under Article 23(1) of Inda-USA tax treaty, was taxable in India. As a corollary to these findings, in our considered view, the assessee

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