Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
TDS u/s 195 was not applicable on commission paid to non-resident agents for services rendered outside India. The assessee hired agents in foreign countries where it did not have a physical presence to assist in procuring contracts. The commission payments were made for services rendered outside India and were not chargeable to tax in India. In the absence of chargeability to tax, the provisions of Section 195 of the Act were not attracted, as rightly held by the CIT(A). The CIT(A)'s action granting relief to the assessee was in sync with the Tribunal's view in the assessee's own case for the Assessment Year 2017-18. The Revenue's contentions were unfounded on facts and law. The decision was against the Revenue.
TDS u/s 195 was not applicable on commission paid to non-resident agents for services rendered outside India. The assessee hired agents in foreign countries where it did not have a physical presence to assist in procuring contracts. The commission payments were made for services rendered outside India and were not chargeable to tax in India. In the absence of chargeability to tax, the provisions of Section 195 of the Act were not attracted, as rightly held by the CIT(A). The CIT(A)'s action granting relief to the assessee was in sync with the Tribunal's view in the assessee's own case for the Assessment Year 2017-18. The Revenue's contentions were unfounded on facts and law. The decision was against the Revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
