https://www.taxtmi.com/caselaws?id=393808 Payment to a non-resident celebrity for appearing at an overseas launch event was treated as taxable in India because the engagement was integrally connected with an Indian business promotion and commercial benefit in India. Applying section 5(2)(b) read with section 9(1)(i), the analysis stated that income earned outside India may still arise through a business connection in India and be subject to source taxation. The treaty argument under the residuary article was rejected on the basis that domestic law taxation was not excluded, and section 115BBA did not limit chargeability. As the payment was taxable in India, withholding obligations under sections 195 and 201 followed. en-us Thu, 19 Mar 2020 00:00:00 +0530 Wed, 24 Jun 2020 14:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393808 Payment to a non-resident celebrity for appearing at an overseas launch event was treated as taxable in India because the engagement was integrally connected with an Indian business promotion and commercial benefit in India. Applying section 5(2)(b) read with section 9(1)(i), the analysis stated that income earned outside India may still arise through a business connection in India and be subject to source taxation. The treaty argument under the residuary article was rejected on the basis that domestic law taxation was not excluded, and section 115BBA did not limit chargeability. As the payment was taxable in India, withholding obligations under sections 195 and 201 followed. Case-Laws Income Tax Thu, 19 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393808