https://www.taxtmi.com/caselaws?id=354148 The Tribunal dismissed the revenue's appeal, upholding the Ld. CIT(A)'s decision to delete the disallowance under section 40(a)(i) of the Income Tax Act, 1961. It was determined that the commission paid to non-resident agents for services provided outside India was not subject to tax deduction in India. The Tribunal emphasized the lack of income accrual or arising in India due to the absence of a Permanent Establishment. However, the judgment did not delve into the details of the disallowance under section 14A of the Act. en-us Wed, 10 Jan 2018 00:00:00 +0530 Fri, 19 Jan 2018 08:18:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354148 The Tribunal dismissed the revenue's appeal, upholding the Ld. CIT(A)'s decision to delete the disallowance under section 40(a)(i) of the Income Tax Act, 1961. It was determined that the commission paid to non-resident agents for services provided outside India was not subject to tax deduction in India. The Tribunal emphasized the lack of income accrual or arising in India due to the absence of a Permanent Establishment. However, the judgment did not delve into the details of the disallowance under section 14A of the Act. Case-Laws Income Tax Wed, 10 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354148