Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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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