I'd made the payment to non-resident for the production cost of advertisement of my product which was going to be displayed at delhi airport. I'd made the payment after deducting TDS u/s 195. Party is arguing that as the productin took place overseas, hence income does not accrue or arise in India. My argument is that the same advertisement is been published at Delh airport ie India which, so it accrues and arise in India. Kindly suggest me the correct measure for the same.
CAclubindia
