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No international transaction due to lack of pre-requisite agreement; Shilpa Shetty gets another favourable ruling

June 25, 2019[2019] 106 taxmann.com 304 (Mumbai - Trib.)
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IT/ILT : Brand ambassadorship services by Shilpa Shetty to Jaipur IPL Team is not an international transaction

International Taxation : Where assessee acted as brand ambassador for Jaipur IPL Team and she involved herself in Cricket Matches, photo shoots, press interviews, personal appearances etc. but no receipts were reflected by her during assessment year on account of rendering of these services, section 92B(2) cannot be applied to hold that transaction between assessee and JICPL was an 'International transaction' as pre-requisite of a prior agreement between a non-AE with the AE of assessee is not fulfilled

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