https://www.taxtmi.com/caselaws?id=279249 The ITAT upheld the CIT(A)'s decision, ruling in favor of the appellant by deleting the addition of Rs. 63,08,727. The tribunal found that the commission paid to foreign agents for services outside India did not attract TDS under Section 195 due to the absence of a business connection or permanent establishment in India. The withdrawal of CBDT Circulars did not alter the tax liability landscape, and the provisions of Sections 5(2) and 9(1)(i) were deemed inapplicable. The appeal was dismissed, affirming the CIT(A)'s decision. en-us Thu, 28 Sep 2017 00:00:00 +0530 Sat, 09 Mar 2019 07:01:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279249 The ITAT upheld the CIT(A)'s decision, ruling in favor of the appellant by deleting the addition of Rs. 63,08,727. The tribunal found that the commission paid to foreign agents for services outside India did not attract TDS under Section 195 due to the absence of a business connection or permanent establishment in India. The withdrawal of CBDT Circulars did not alter the tax liability landscape, and the provisions of Sections 5(2) and 9(1)(i) were deemed inapplicable. The appeal was dismissed, affirming the CIT(A)'s decision. Case-Laws Income Tax Thu, 28 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279249