Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
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Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
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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