Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Commission paid to non-resident agents for procuring export orders through services rendered outside India is not chargeable to tax in India merely because it relates to an Indian exporter's business. Tax deduction at source on such payments arises only where the income is chargeable to tax in India. In the absence of material showing that the agents rendered services in India or maintained a permanent establishment or business operations in India, the commission remains outside Indian tax charge. Consequently, no tax was deductible on the foreign commission payments, and the corresponding disallowance for non-deduction of tax at source was deleted.
Commission paid to non-resident agents for procuring export orders through services rendered outside India is not chargeable to tax in India merely because it relates to an Indian exporter's business. Tax deduction at source on such payments arises only where the income is chargeable to tax in India. In the absence of material showing that the agents rendered services in India or maintained a permanent establishment or business operations in India, the commission remains outside Indian tax charge. Consequently, no tax was deductible on the foreign commission payments, and the corresponding disallowance for non-deduction of tax at source was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
