https://www.taxtmi.com/caselaws?id=388939 The Tribunal upheld the CIT(A)'s decision to dismiss the disallowance of commission paid to two directors under Section 36(1)(ii), citing a structured remuneration plan approved by the Board and no tax avoidance motive. Regarding disallowance under Section 14A read with Rule 8D, the Tribunal remanded the matter back to the AO for re-examination as proper justification for invoking Rule 8D was lacking. The Tribunal affirmed the deletion of disallowance under Section 40(a)(ia) for non-deduction of TDS on payments to foreign parties, stating no TDS was required as services did not qualify as "fees for technical services" under relevant DTAAs. en-us Mon, 25 Nov 2019 00:00:00 +0530 Wed, 27 Nov 2019 13:46:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388939 The Tribunal upheld the CIT(A)'s decision to dismiss the disallowance of commission paid to two directors under Section 36(1)(ii), citing a structured remuneration plan approved by the Board and no tax avoidance motive. Regarding disallowance under Section 14A read with Rule 8D, the Tribunal remanded the matter back to the AO for re-examination as proper justification for invoking Rule 8D was lacking. The Tribunal affirmed the deletion of disallowance under Section 40(a)(ia) for non-deduction of TDS on payments to foreign parties, stating no TDS was required as services did not qualify as "fees for technical services" under relevant DTAAs. Case-Laws Income Tax Mon, 25 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388939