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    <title>2019 (5) TMI 1602 - ITAT DELHI</title>
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    <description>The Tribunal dismissed the revenue&#039;s appeals for Assessment Years 2011-12 and 2012-13, affirming the CIT(A)&#039;s decision to delete the disallowance of commission payments to foreign agents. It held that the foreign agents had no business connection in India and the services were rendered outside India, making the commission payments not taxable in India. The withdrawal of Circular Nos. 23/1969 and 786/2000 did not alter the taxability of such payments. The Tribunal ruled that the provisions of Section 195 were not applicable as the commission payments did not meet the criteria for tax liability in India.</description>
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    <pubDate>Tue, 28 May 2019 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=380874</link>
      <description>The Tribunal dismissed the revenue&#039;s appeals for Assessment Years 2011-12 and 2012-13, affirming the CIT(A)&#039;s decision to delete the disallowance of commission payments to foreign agents. It held that the foreign agents had no business connection in India and the services were rendered outside India, making the commission payments not taxable in India. The withdrawal of Circular Nos. 23/1969 and 786/2000 did not alter the taxability of such payments. The Tribunal ruled that the provisions of Section 195 were not applicable as the commission payments did not meet the criteria for tax liability in India.</description>
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      <pubDate>Tue, 28 May 2019 00:00:00 +0530</pubDate>
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