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    <title>2018 (12) TMI 116 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the CIT(A)&#039;s decision to delete disallowance under section 40(a)(i) of the Income Tax Act for professional fees paid to non-residents without tax deduction at source under section 195. It was determined that the payments were not chargeable to tax in India as the services did not involve the transfer of technical knowledge and the non-residents had no permanent establishment in India. Therefore, the Tribunal dismissed the Revenue&#039;s appeal, affirming the CIT(A)&#039;s order and ruling in favor of the assessee.</description>
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    <pubDate>Wed, 28 Nov 2018 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=371347</link>
      <description>The Tribunal upheld the CIT(A)&#039;s decision to delete disallowance under section 40(a)(i) of the Income Tax Act for professional fees paid to non-residents without tax deduction at source under section 195. It was determined that the payments were not chargeable to tax in India as the services did not involve the transfer of technical knowledge and the non-residents had no permanent establishment in India. Therefore, the Tribunal dismissed the Revenue&#039;s appeal, affirming the CIT(A)&#039;s order and ruling in favor of the assessee.</description>
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      <pubDate>Wed, 28 Nov 2018 00:00:00 +0530</pubDate>
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