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The Appellate Tribunal addressed the issue of TDS u/s 195 on sub contract charges paid to a Singapore company. The Non-Resident company argued it falls under Section 44BB, exempting it from TDS. The Tribunal found the company covered by Section 44BB and the Singapore company has no Permanent Establishment in India, making the payments non-taxable. Consequently, the disallowance u/s 40(a)(ia) was not applicable. The addition by the Assessing Officer was deleted, and the assessee's appeal was allowed.
The Appellate Tribunal addressed the issue of TDS u/s 195 on sub contract charges paid to a Singapore company. The Non-Resident company argued it falls under Section 44BB, exempting it from TDS. The Tribunal found the company covered by Section 44BB and the Singapore company has no Permanent Establishment in India, making the payments non-taxable. Consequently, the disallowance u/s 40(a)(ia) was not applicable. The addition by the Assessing Officer was deleted, and the assessee's appeal was allowed.
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