https://www.taxtmi.com/caselaws?id=267766 The disallowance of commission payment to foreign agents under section 40(a)(i) of the Income-tax Act, 1961 was contested in this case. The Assessing Officer disallowed the payment due to failure to deduct tax at source under section 195. The Commissioner of Income-tax (Appeals) upheld the disallowance, but the ITAT ruled in favor of the appellant. The ITAT emphasized that tax deduction was required only on income chargeable under the Act, and as there was no evidence that the payments were taxable in India, the disallowance was overturned. The appellant's appeal was allowed, and the addition of the commission payment was deleted. en-us Wed, 01 Apr 2015 00:00:00 +0530 Sat, 14 Nov 2015 12:15:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267766 The disallowance of commission payment to foreign agents under section 40(a)(i) of the Income-tax Act, 1961 was contested in this case. The Assessing Officer disallowed the payment due to failure to deduct tax at source under section 195. The Commissioner of Income-tax (Appeals) upheld the disallowance, but the ITAT ruled in favor of the appellant. The ITAT emphasized that tax deduction was required only on income chargeable under the Act, and as there was no evidence that the payments were taxable in India, the disallowance was overturned. The appellant's appeal was allowed, and the addition of the commission payment was deleted. Case-Laws Income Tax Wed, 01 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267766