https://www.taxtmi.com/caselaws?id=280364 The Tribunal allowed the appeal, setting aside the order of the Commissioner of Income Tax (Appeals) regarding the disallowance under Section 40(a)(i) of the Income Tax Act. It was held that the commission payments made to the non-resident agent for services rendered outside India were not taxable in India, as per the provisions of the Double Taxation Avoidance Agreement between India and the USA. Therefore, Section 195 was deemed inapplicable, leading to the conclusion that the disallowance was not justified. en-us Fri, 20 Jul 2018 00:00:00 +0530 Thu, 02 May 2019 07:39:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280364 The Tribunal allowed the appeal, setting aside the order of the Commissioner of Income Tax (Appeals) regarding the disallowance under Section 40(a)(i) of the Income Tax Act. It was held that the commission payments made to the non-resident agent for services rendered outside India were not taxable in India, as per the provisions of the Double Taxation Avoidance Agreement between India and the USA. Therefore, Section 195 was deemed inapplicable, leading to the conclusion that the disallowance was not justified. Case-Laws Income Tax Fri, 20 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280364