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TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered by MSI do not fall within the ambit of Fees for Technical Services (FTS) or under Article 12 of the DTAA between India and the USA. The payment was for sales and marketing services, not constituting FTS or royalty, and did not require TDS deduction. The Revenue's appeal on this matter dismissed.
TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered by MSI do not fall within the ambit of Fees for Technical Services (FTS) or under Article 12 of the DTAA between India and the USA. The payment was for sales and marketing services, not constituting FTS or royalty, and did not require TDS deduction. The Revenue's appeal on this matter dismissed.
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