Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
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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