https://www.taxtmi.com/highlights?id=55795 Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for earning commission cannot be of such a nature that there is a transfer of technology, in the sense it is required to fulfil the 'make available' clause in the Indo UK DTAA. - even if the commission income in the hands of the recipient is taxable under the provisions of Section 9, the provisions of the Indo UK DTAA will come to the rescue of the assessee. - AT en-us Tue, 08 Dec 2020 11:22:12 +0530 Tue, 08 Dec 2020 11:22:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=55795 Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for earning commission cannot be of such a nature that there is a transfer of technology, in the sense it is required to fulfil the 'make available' clause in the Indo UK DTAA. - even if the commission income in the hands of the recipient is taxable under the provisions of Section 9, the provisions of the Indo UK DTAA will come to the rescue of the assessee. - AT Highlights Income Tax Tue, 08 Dec 2020 11:22:12 +0530 https://www.taxtmi.com/highlights?id=55795