Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT Mumbai ruled on TDS u/s 195 regarding commission paid to foreign agents for procuring export orders. The assessee paid commission to non-resident agents outside India, residents of countries with DTAA with India. The Tribunal noted services were rendered outside India, agents had no PE in India, and payments were based on export orders procured. Previous cases showed commission was for procuring export orders, not income accruing in India. Tribunal upheld Ld. CIT(A)'s decision that commission earned by non-resident agents selling Indian goods abroad is not deemed to accrue in India. Decision favored the assessee.
The ITAT Mumbai ruled on TDS u/s 195 regarding commission paid to foreign agents for procuring export orders. The assessee paid commission to non-resident agents outside India, residents of countries with DTAA with India. The Tribunal noted services were rendered outside India, agents had no PE in India, and payments were based on export orders procured. Previous cases showed commission was for procuring export orders, not income accruing in India. Tribunal upheld Ld. CIT(A)'s decision that commission earned by non-resident agents selling Indian goods abroad is not deemed to accrue in India. Decision favored the assessee.
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