Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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 4891 
