Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
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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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