https://www.taxtmi.com/caselaws?id=185877 The Appellate Tribunal ITAT Hyderabad upheld the decision to dismiss the appeal regarding the disallowance of expenditure under section 40(a)(i) for failure to deduct tax at source while making payments outside India. The Tribunal found that since the payments were made by the branch office of the assessee in the USA to foreign agents outside India, and the foreign agents did not have a permanent establishment in India, the provisions of section 195(1) did not apply. Therefore, the disallowance made by the Assessing Officer was deemed unjustified, and the CIT (A)'s deletion of the addition was upheld. en-us Fri, 20 Nov 2009 00:00:00 +0530 Thu, 01 Sep 2016 13:02:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185877 The Appellate Tribunal ITAT Hyderabad upheld the decision to dismiss the appeal regarding the disallowance of expenditure under section 40(a)(i) for failure to deduct tax at source while making payments outside India. The Tribunal found that since the payments were made by the branch office of the assessee in the USA to foreign agents outside India, and the foreign agents did not have a permanent establishment in India, the provisions of section 195(1) did not apply. Therefore, the disallowance made by the Assessing Officer was deemed unjustified, and the CIT (A)'s deletion of the addition was upheld. Case-Laws Income Tax Fri, 20 Nov 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185877