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    <title>2015 (3) TMI 754 - ITAT PANAJI</title>
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    <description>Commission paid to a resident broker for introducing buyer and seller of iron ore was treated as allowable business expenditure because the service was rendered, the recipient had returned the income, and no colourable device was shown. Commission paid to a non-resident agent was also allowed, as the agent had no permanent establishment in India and the income was not chargeable to tax in India, so no tax deduction obligation arose under section 195 and disallowance under section 40(a)(i) could not stand. Restricted disallowance of transportation and labour s was sustained due to inadequate vouchers. Crushing and screening charges paid to a sister concern were not disallowed in the absence of any finding of excessiveness under section 40A(2). Demurrage disallowance was restored following binding precedent on tax deduction.</description>
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      <description>Commission paid to a resident broker for introducing buyer and seller of iron ore was treated as allowable business expenditure because the service was rendered, the recipient had returned the income, and no colourable device was shown. Commission paid to a non-resident agent was also allowed, as the agent had no permanent establishment in India and the income was not chargeable to tax in India, so no tax deduction obligation arose under section 195 and disallowance under section 40(a)(i) could not stand. Restricted disallowance of transportation and labour s was sustained due to inadequate vouchers. Crushing and screening charges paid to a sister concern were not disallowed in the absence of any finding of excessiveness under section 40A(2). Demurrage disallowance was restored following binding precedent on tax deduction.</description>
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