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    <title>2013 (5) TMI 879 - ITAT LUCKNOW</title>
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    <description>Commission paid to non-resident agents for services rendered outside India was held not to attract tax deduction at source where the amount was not shown to be chargeable in India, the services were not technical, consultancy or managerial, and the later CBDT withdrawal operated prospectively. The disallowance under section 40(a)(i) was therefore not warranted. Premium paid on insurance policies taken by a firm in the names of its partners was treated as deductible revenue expenditure because the policies were, in substance, a keyman-type arrangement intended to protect the business against loss on a partner&#039;s death. The allowance under section 37(1) was upheld subject to the assessee&#039;s undertaking regarding taxability of maturity proceeds.</description>
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    <pubDate>Tue, 28 May 2013 00:00:00 +0530</pubDate>
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      <title>2013 (5) TMI 879 - ITAT LUCKNOW</title>
      <link>https://www.taxtmi.com/caselaws?id=180334</link>
      <description>Commission paid to non-resident agents for services rendered outside India was held not to attract tax deduction at source where the amount was not shown to be chargeable in India, the services were not technical, consultancy or managerial, and the later CBDT withdrawal operated prospectively. The disallowance under section 40(a)(i) was therefore not warranted. Premium paid on insurance policies taken by a firm in the names of its partners was treated as deductible revenue expenditure because the policies were, in substance, a keyman-type arrangement intended to protect the business against loss on a partner&#039;s death. The allowance under section 37(1) was upheld subject to the assessee&#039;s undertaking regarding taxability of maturity proceeds.</description>
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      <pubDate>Tue, 28 May 2013 00:00:00 +0530</pubDate>
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