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    <title>2018 (4) TMI 517 - ITAT DELHI</title>
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    <description>The note examines four income-tax issues: polishing charges, depreciation on electrical fittings, interest disallowance on advances, and withholding on foreign commission. It states that where expenditure is supported by PAN details, quantitative records, partial confirmations and tax deduction at source, a blanket disallowance is not justified, though a limited estimated disallowance may remain on verification gaps. It also explains that electrical fittings were treated as furniture and fittings, attracting 10% depreciation rather than 15%. On interest-free advances, the availability of sufficient interest-free funds and the mixed-funds presumption required factual verification. For foreign commission paid to non-resident agents for services rendered outside India, with no permanent establishment or income accruing in India, section 195 withholding and section 40(a)(ia) disallowance were not attracted.</description>
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    <pubDate>Mon, 09 Apr 2018 00:00:00 +0530</pubDate>
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      <title>2018 (4) TMI 517 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=358406</link>
      <description>The note examines four income-tax issues: polishing charges, depreciation on electrical fittings, interest disallowance on advances, and withholding on foreign commission. It states that where expenditure is supported by PAN details, quantitative records, partial confirmations and tax deduction at source, a blanket disallowance is not justified, though a limited estimated disallowance may remain on verification gaps. It also explains that electrical fittings were treated as furniture and fittings, attracting 10% depreciation rather than 15%. On interest-free advances, the availability of sufficient interest-free funds and the mixed-funds presumption required factual verification. For foreign commission paid to non-resident agents for services rendered outside India, with no permanent establishment or income accruing in India, section 195 withholding and section 40(a)(ia) disallowance were not attracted.</description>
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      <pubDate>Mon, 09 Apr 2018 00:00:00 +0530</pubDate>
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