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    <title>2019 (1) TMI 1400 - ITAT DELHI</title>
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    <description>The appeal by the revenue against the disallowance of interest on intercorporate loans and commission payment without TDS deduction was dismissed. The Tribunal upheld the CIT(A)&#039;s decisions, ruling that the interest disallowance was not justified as the advance was for a business purpose and part of it was refunded. Regarding the commission payment, it was deemed non-taxable in India as the recipient had no permanent establishment in India, leading to the deletion of the disallowance. The Tribunal&#039;s decision was supported by a Gujarat High Court ruling.</description>
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      <link>https://www.taxtmi.com/caselaws?id=374235</link>
      <description>The appeal by the revenue against the disallowance of interest on intercorporate loans and commission payment without TDS deduction was dismissed. The Tribunal upheld the CIT(A)&#039;s decisions, ruling that the interest disallowance was not justified as the advance was for a business purpose and part of it was refunded. Regarding the commission payment, it was deemed non-taxable in India as the recipient had no permanent establishment in India, leading to the deletion of the disallowance. The Tribunal&#039;s decision was supported by a Gujarat High Court ruling.</description>
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