Appeal allowed: Domestic service payments excluded from transaction value under Valuation Rules; CKD subassemblies deemed non-motor vehicles, get conc...
ITAT allowed the taxpayer's appeal against the Assessing Officer and CIT(A)'s treatment of the taxpayer as a defaulter under ss. 201(1)/201(1A) arising from TDS on commission payments to non-residents. The Tribunal held that the taxpayer produced requisite Form 15CBs for each non-resident remittance, applied the applicable DTAA positions, and deposited tax at source as required; accordingly there was no default under s. 201(1) r.w.s. 201(1A) or basis to sustain disallowances under s. 40(a)(i) r.w.s. 195. The impugned findings against the taxpayer were set aside and the appeal allowed.
ITAT allowed the taxpayer's appeal against the Assessing Officer and CIT(A)'s treatment of the taxpayer as a defaulter under ss. 201(1)/201(1A) arising from TDS on commission payments to non-residents. The Tribunal held that the taxpayer produced requisite Form 15CBs for each non-resident remittance, applied the applicable DTAA positions, and deposited tax at source as required; accordingly there was no default under s. 201(1) r.w.s. 201(1A) or basis to sustain disallowances under s. 40(a)(i) r.w.s. 195. The impugned findings against the taxpayer were set aside and the appeal allowed.
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