https://www.taxtmi.com/caselaws?id=372377 The Appellate Tribunal's decision was upheld in favor of the assessee regarding the disallowance under Section 40(a)(i) of the Income Tax Act. The Tribunal ruled that the payment to a foreign company for technical services, utilized outside India for business purposes, did not attract tax liability in India. The payment received by the foreign company was deemed not taxable under Section 9(1)(vii) of the Act as the services were provided outside India for the assessee's overseas clients. The Court emphasized the importance of determining tax liability based on the source of income and upheld the Tribunal's decision, dismissing the Tax Appeal. en-us Tue, 16 Oct 2018 00:00:00 +0530 Thu, 20 Dec 2018 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=372377 The Appellate Tribunal's decision was upheld in favor of the assessee regarding the disallowance under Section 40(a)(i) of the Income Tax Act. The Tribunal ruled that the payment to a foreign company for technical services, utilized outside India for business purposes, did not attract tax liability in India. The payment received by the foreign company was deemed not taxable under Section 9(1)(vii) of the Act as the services were provided outside India for the assessee's overseas clients. The Court emphasized the importance of determining tax liability based on the source of income and upheld the Tribunal's decision, dismissing the Tax Appeal. Case-Laws Income Tax Tue, 16 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=372377