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    <title>2016 (5) TMI 73 - ITAT KOLKATA</title>
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    <description>The Tribunal held that the assessee was not liable to deduct tax at source on payments to overseas entities for logistic services as the income was not chargeable to tax in India. It was determined that the income of the overseas entities did not accrue or arise in India, and the assessee was not appointed as an &#039;Exclusive Agent&#039; but operated on a principal-to-principal basis. Additionally, the assessee did not qualify as a &quot;Dependent Agent&quot; or &quot;Permanent Establishment&quot; of the overseas entities in India under various Double Taxation Avoidance Agreements. The Tribunal allowed the appeal of the assessee, reversing the decisions of lower authorities.</description>
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      <title>2016 (5) TMI 73 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=327092</link>
      <description>The Tribunal held that the assessee was not liable to deduct tax at source on payments to overseas entities for logistic services as the income was not chargeable to tax in India. It was determined that the income of the overseas entities did not accrue or arise in India, and the assessee was not appointed as an &#039;Exclusive Agent&#039; but operated on a principal-to-principal basis. Additionally, the assessee did not qualify as a &quot;Dependent Agent&quot; or &quot;Permanent Establishment&quot; of the overseas entities in India under various Double Taxation Avoidance Agreements. The Tribunal allowed the appeal of the assessee, reversing the decisions of lower authorities.</description>
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      <pubDate>Wed, 27 Apr 2016 00:00:00 +0530</pubDate>
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