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    <title>2018 (10) TMI 715 - ITAT CHENNAI</title>
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    <description>The Tribunal ruled in favor of the assessee regarding the addition made under Section 40(a)(ia) for payments to overseas entities without tax deduction under Section 195. The High Court held that such payments were not subject to tax deduction in India as they did not constitute &quot;fees for technical services&quot; and were performed outside India. Consequently, the additions for the relevant assessment years were deleted. Regarding the addition under Rule 14A read with Rule 8D(iii) for the assessment year 2010-11, the Tribunal remitted the matter back to the AO for proper computation of actual expenses towards earning exempt income. The appeals were partly allowed, and the Tribunal&#039;s order was pronounced in Chennai on July 23, 2018.</description>
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      <title>2018 (10) TMI 715 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=368749</link>
      <description>The Tribunal ruled in favor of the assessee regarding the addition made under Section 40(a)(ia) for payments to overseas entities without tax deduction under Section 195. The High Court held that such payments were not subject to tax deduction in India as they did not constitute &quot;fees for technical services&quot; and were performed outside India. Consequently, the additions for the relevant assessment years were deleted. Regarding the addition under Rule 14A read with Rule 8D(iii) for the assessment year 2010-11, the Tribunal remitted the matter back to the AO for proper computation of actual expenses towards earning exempt income. The appeals were partly allowed, and the Tribunal&#039;s order was pronounced in Chennai on July 23, 2018.</description>
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