Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Commission paid to a non-resident agent for services rendered outside India was treated as not giving rise to income accruing or arising in India, so section 195 was held inapplicable and the related section 40(a)(i) disallowance could not stand. The Tribunal also sustained the deletion of disallowance on ocean freight paid to non-resident shipping lines or their agents, accepting that tax had already been deducted on payments to residents and that the balance freight was not liable for TDS in view of CBDT Circular No. 723. The Revenue produced no material to disturb the CIT(A)'s findings, so the appellate relief was affirmed.
Commission paid to a non-resident agent for services rendered outside India was treated as not giving rise to income accruing or arising in India, so section 195 was held inapplicable and the related section 40(a)(i) disallowance could not stand. The Tribunal also sustained the deletion of disallowance on ocean freight paid to non-resident shipping lines or their agents, accepting that tax had already been deducted on payments to residents and that the balance freight was not liable for TDS in view of CBDT Circular No. 723. The Revenue produced no material to disturb the CIT(A)'s findings, so the appellate relief was affirmed.
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