Description:
In case where service were rendered outside India and there was no PE, The same was not assessable to tax in India. Even under the Act, by virtue of Carborandum Co 108 ITR 335 (sc), Circular No.17 of 1953 dated 17-7-1953 & Circular No.786 dated 7-2-2000, commission paid to agents for services rendered outside India is not chargeable to tax in India and there is no obligation to deduct tax u/s 195.
ADIT vs. Wizacraft International Entertainment (ITAT-Mum.)
Source:
1. www.Itatonline.org
2.AIFTP TIMES.Volume.No.12 December,2010.Page No.7.
Our Comment:
Agents for foreign artists are not taxable in India there is no PE in India. If Agents have rendered services outside India.
