The assessee paid US $ 4,40,000 in respect of a celebrity appearance at Dubai without withholding any tax from the remittance. The Assessing Officer held that the payment made to the celebrity was taxable in India particularly as royalty under section 9(1)(vi) of the Income-tax Act, 1961 . He examined the provisions of article 12 of the Double Taxation Avoidance Agreement between India and the U. S. A. and held that the provisions thereof did not come to the rescue of the assessee. The Commissioner (Appeals) not only confirmed the action of the Assessing Officer but held that the whole purpose of organising an India centric event at Dubai was to avoid attraction of the clause regarding income accruing or arising in India and referred to the provisions of section 9(1)(i) . He confirmed the withholding demand under section 201 read with section 195 . On appeal the Tribunal affiriming the oder of the CIT (A) held that , the  target audience in India, potential customers in India, intended benefits in India  therefore  business connection is established hence the assessee is  liable to deduct tax at source   ( AY.2015-16)