Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
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