Income of NR agent for arranging NR Artists in India not taxable in status of ‘Entertainer’ under In

IT/ILT : The assessee, an event management company, engaged the services of a non-resident agent to bring the foreign Artists to India. The assessee paid remuneration to the Artists and commission to the agent. It deducted tax on the amounts paid to the Artists but did not deduct tax on the commission paid to the agents. Whether the sum paid to agent could not be deemed to have arisen from the personal activities in a contracting State in status of entertainer or athlete - Held, yes - Whether co