https://www.taxtmi.com/caselaws?id=173713 The Tribunal dismissed the Revenue's appeal and upheld the decision of the CIT(A), ruling in favor of the assessee. It was held that the commission paid to the foreign agent was not taxable in India and thus not subject to TDS under Section 195 of the Income-tax Act. The Tribunal emphasized the importance of applying circulars in force during the relevant assessment years and clarified that subsequent circulars do not have retrospective effect. The appeal by the Revenue was therefore dismissed, affirming the deletion of the disallowance under Section 40(a)(i) of the Act. en-us Fri, 07 Jan 2011 00:00:00 +0530 Tue, 16 May 2023 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173713 The Tribunal dismissed the Revenue's appeal and upheld the decision of the CIT(A), ruling in favor of the assessee. It was held that the commission paid to the foreign agent was not taxable in India and thus not subject to TDS under Section 195 of the Income-tax Act. The Tribunal emphasized the importance of applying circulars in force during the relevant assessment years and clarified that subsequent circulars do not have retrospective effect. The appeal by the Revenue was therefore dismissed, affirming the deletion of the disallowance under Section 40(a)(i) of the Act. Case-Laws Income Tax Fri, 07 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=173713