https://www.taxtmi.com/caselaws?id=120575 The Tribunal dismissed the revenue's appeals and upheld the assessee's positions. It confirmed that the reassessment proceedings under section 147 were time-barred and based on a change of opinion. The commission payments to foreign agents were deemed genuine and necessary for business, with no evidence of impropriety. The Tribunal ruled that no tax was deductible on these payments under section 40(a)(i) as the services were rendered outside India. Additionally, the Tribunal allowed the deduction for bad debts written off, recognizing them as legitimate business expenses. en-us Mon, 31 Mar 2008 00:00:00 +0530 Wed, 20 Dec 2023 17:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120575 The Tribunal dismissed the revenue's appeals and upheld the assessee's positions. It confirmed that the reassessment proceedings under section 147 were time-barred and based on a change of opinion. The commission payments to foreign agents were deemed genuine and necessary for business, with no evidence of impropriety. The Tribunal ruled that no tax was deductible on these payments under section 40(a)(i) as the services were rendered outside India. Additionally, the Tribunal allowed the deduction for bad debts written off, recognizing them as legitimate business expenses. Case-Laws Income Tax Mon, 31 Mar 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120575