Sum received for Line production services for shooting of ‘Fear Factor’ in SA not FTS or Royalty

IT : Where Endemol India, commissioned to produce television series, viz., 'Fear Factor', based on US version/format of same for broadcast in India for shooting Episodes in South Africa, had vide agreement hired assessee (Endemol South Africa engaged in business of developing and producing entertainment serials for audio-visual platform) for carrying out Line Production Services in South Africa on work-for-hire basis, since various coordination/facilitation services rendered by assessee, viz.,

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