https://www.taxtmi.com/caselaws?id=416568 The Tribunal ruled in favor of the assessee in a case involving disallowance of commission payments to non-resident agents under section 40(a)(i) for non-deduction of tax at source. The Tribunal held that the services provided by the foreign agents were primarily marketing support services, not falling under "Fee for Technical Services" (FTS), and thus no income chargeable in India accrued to the foreign agents. Consequently, the assessee was not liable to deduct tax at source for the payments made to foreign agents. The Tribunal also allowed the assessee's appeal regarding transfer pricing adjustments for AY 2012-13, directing the exclusion of certain comparable companies and disregarding negative working capital adjustments. en-us Wed, 15 Dec 2021 00:00:00 +0530 Fri, 31 Dec 2021 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416568 The Tribunal ruled in favor of the assessee in a case involving disallowance of commission payments to non-resident agents under section 40(a)(i) for non-deduction of tax at source. The Tribunal held that the services provided by the foreign agents were primarily marketing support services, not falling under "Fee for Technical Services" (FTS), and thus no income chargeable in India accrued to the foreign agents. Consequently, the assessee was not liable to deduct tax at source for the payments made to foreign agents. The Tribunal also allowed the assessee's appeal regarding transfer pricing adjustments for AY 2012-13, directing the exclusion of certain comparable companies and disregarding negative working capital adjustments. Case-Laws Income Tax Wed, 15 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416568