Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Claim of deduction u/s 10A / 10AA on Disallowance made u/s 40(a)(ia) due to non deduction of TDS - Business Development Commission paid to its US based Associated Enterprises (AE) - there was no requirement on the part of the assessee to deduct TDS on such payments and accordingly, no disallowance u/s 40(a)(i) would be attracted - Since, the disallowance itself do not survive, the grounds raised in cross-appeal stand dismissed as infructuous. The assessee’s appeal stand dismissed as infructuous. - AT
Claim of deduction u/s 10A / 10AA on Disallowance made u/s 40(a)(ia) due to non deduction of TDS - Business Development Commission paid to its US based Associated Enterprises (AE) - there was no requirement on the part of the assessee to deduct TDS on such payments and accordingly, no disallowance u/s 40(a)(i) would be attracted - Since, the disallowance itself do not survive, the grounds raised in cross-appeal stand dismissed as infructuous. The assessee’s appeal stand dismissed as infructuous. - AT
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