Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The ITAT Delhi ruled on TDS u/s 195 and disallowance u/s 40(a)(i) for non-deduction of tax on shipment clearing and forwarding charges. The AO considered the services as consultancy, requiring tax deduction. However, CIT(A) deleted the addition, stating the income did not accrue in India. The AO's basis was advice on tariff ratio, but the ITAT found it insufficient to classify as consultancy. Merely providing information does not equate to consultancy services. The decision favored the assessee as the income was not deemed to accrue in India.
The ITAT Delhi ruled on TDS u/s 195 and disallowance u/s 40(a)(i) for non-deduction of tax on shipment clearing and forwarding charges. The AO considered the services as consultancy, requiring tax deduction. However, CIT(A) deleted the addition, stating the income did not accrue in India. The AO's basis was advice on tariff ratio, but the ITAT found it insufficient to classify as consultancy. Merely providing information does not equate to consultancy services. The decision favored the assessee as the income was not deemed to accrue in India.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
