Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
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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.
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