Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Page of 4798
Press 'Enter' after typing page number.
621 to 640 of 95957 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT held that sums paid as commission to foreign agents and overseas warehousing charges constituted business income arising outside India and were not chargeable here; consequently no obligation to deduct tax under s.195 arose and disallowance under s.40(a)(ia) could not be sustained. The Tribunal found absence of business connection or PE in India and rejected characterization of the payments as FTS, observing that agents merely canvassed orders and warehouses provided space (rent), not managerial or technical services. As the receipts lacked territorial nexus and were not income chargeable under the Act, the revenue's additions were reversed and the taxpayer's appeal was allowed.
ITAT held that sums paid as commission to foreign agents and overseas warehousing charges constituted business income arising outside India and were not chargeable here; consequently no obligation to deduct tax under s.195 arose and disallowance under s.40(a)(ia) could not be sustained. The Tribunal found absence of business connection or PE in India and rejected characterization of the payments as FTS, observing that agents merely canvassed orders and warehouses provided space (rent), not managerial or technical services. As the receipts lacked territorial nexus and were not income chargeable under the Act, the revenue's additions were reversed and the taxpayer's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
