https://www.taxtmi.com/caselaws?id=247222 Commission paid to a non-resident agent for services rendered outside India in contacting and negotiating with foreign artists was not taxable in India under Article 18 of the Indo-UK DTAA, because the agent did not perform any personal activities in India as an entertainer or athlete. Documented reimbursement of travel and related performance expenses was likewise not treated as income derived from personal activities in India. As tax had already been deducted on the artists' performance fees, the commission and reimbursement did not independently attract a withholding obligation. The revenue challenge therefore failed on the taxability and source-deduction issue. en-us Mon, 21 Apr 2014 00:00:00 +0530 Sat, 21 Feb 2015 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247222 Commission paid to a non-resident agent for services rendered outside India in contacting and negotiating with foreign artists was not taxable in India under Article 18 of the Indo-UK DTAA, because the agent did not perform any personal activities in India as an entertainer or athlete. Documented reimbursement of travel and related performance expenses was likewise not treated as income derived from personal activities in India. As tax had already been deducted on the artists' performance fees, the commission and reimbursement did not independently attract a withholding obligation. The revenue challenge therefore failed on the taxability and source-deduction issue. Case-Laws Income Tax Mon, 21 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247222