Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
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.
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