https://www.taxtmi.com/caselaws?id=374288 ITAT AHMEDABAD upheld the assessee's position: commission paid to foreign non-resident agents was not taxable in India under s.195/s.40(a)(ia) because agents had no PE in India and commissions were not fees for technical services; precedent of the SC applied. The AO's disallowance was cancelled and the revenue's appeal dismissed. Separately, disallowance under s.14A/Rule 8D was rejected as investments were made from own funds and no expenditure related to exempt income was debited, so no s.14A adjustment was warranted. Decision for the assessee. en-us Mon, 17 Dec 2018 00:00:00 +0530 Fri, 24 Apr 2026 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374288 ITAT AHMEDABAD upheld the assessee's position: commission paid to foreign non-resident agents was not taxable in India under s.195/s.40(a)(ia) because agents had no PE in India and commissions were not fees for technical services; precedent of the SC applied. The AO's disallowance was cancelled and the revenue's appeal dismissed. Separately, disallowance under s.14A/Rule 8D was rejected as investments were made from own funds and no expenditure related to exempt income was debited, so no s.14A adjustment was warranted. Decision for the assessee. Case-Laws Income Tax Mon, 17 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374288