The Indian Authority for Advance Rulings (AAR) delivered a ruling dated 3 July 2006 in the case of Mr Rajiv Malhotra (unreported) on whether commission paid to a non-resident agent is taxable in India even if the services are rendered outside India (i.e. France).
(a) Facts. The Applicant, Rajiv Malhotra, was an Indian resident engaged in the business of organizing international food and wine shows (IFOWS) in India. The Applicant planned to organize an IFOWS, an…