https://www.taxtmi.com/caselaws?id=383109 The Court dismissed the appeal under Section 260A of the Income Tax Act, 1961 regarding overseas commission payment without tax deduction. It held that nonresidents with no Indian tax liability for income not attributable to operations in India are not subject to disallowance under Section 40(a)(i) or Section 40(a)(ia) for non-deduction of tax at source. The judgment clarified that fees for technical services do not cover order-specific commissions and cited precedents where payments to non-residents for services outside India were not taxable in India. The Court's decision aligned with past rulings, answering substantial legal questions against the Revenue. en-us Fri, 05 Jul 2019 00:00:00 +0530 Wed, 17 Jul 2019 11:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383109 The Court dismissed the appeal under Section 260A of the Income Tax Act, 1961 regarding overseas commission payment without tax deduction. It held that nonresidents with no Indian tax liability for income not attributable to operations in India are not subject to disallowance under Section 40(a)(i) or Section 40(a)(ia) for non-deduction of tax at source. The judgment clarified that fees for technical services do not cover order-specific commissions and cited precedents where payments to non-residents for services outside India were not taxable in India. The Court's decision aligned with past rulings, answering substantial legal questions against the Revenue. Case-Laws Income Tax Fri, 05 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383109