https://www.taxtmi.com/caselaws?id=248386 The High Court ruled in favor of the assessee, dismissing the income tax appeal. It held that the disallowance of Rs.1,50,20,871 for non-deduction of income tax under Section 195 was unjustified as there was no evidence that non-resident agents provided specific services requiring TDS deduction. The Court also determined that the payments to non-resident agents did not constitute "FTS" under Section 9(1)(vii) and were not taxable in India, thus exempting the appellant from TDS obligations. The disallowance under Section 40(a)(ia) for commission paid to agents was also rejected due to the lack of evidence of managerial services. en-us Tue, 17 Dec 2013 00:00:00 +0530 Wed, 11 Jun 2014 11:34:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248386 The High Court ruled in favor of the assessee, dismissing the income tax appeal. It held that the disallowance of Rs.1,50,20,871 for non-deduction of income tax under Section 195 was unjustified as there was no evidence that non-resident agents provided specific services requiring TDS deduction. The Court also determined that the payments to non-resident agents did not constitute "FTS" under Section 9(1)(vii) and were not taxable in India, thus exempting the appellant from TDS obligations. The disallowance under Section 40(a)(ia) for commission paid to agents was also rejected due to the lack of evidence of managerial services. Case-Laws Income Tax Tue, 17 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248386