Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
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