https://www.taxtmi.com/caselaws?id=301627 The Appellate Tribunal upheld the orders of the ld. CIT(A) and dismissed both appeals by the Revenue regarding the disallowance of TDS on payments made to foreign entities. The Tribunal confirmed that the payments were rightly treated as commission and not as fee for technical services, based on the previous decision in the assessee's own case for A.Y. 2010-11. The judgment emphasized the distinction between commission and fee for technical services, highlighting that the foreign entity did not have a Permanent Establishment in India and no technical knowledge was transferred, leading to the deletion of the disallowed amount. en-us Wed, 06 Mar 2019 00:00:00 +0530 Wed, 13 Apr 2022 08:37:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301627 The Appellate Tribunal upheld the orders of the ld. CIT(A) and dismissed both appeals by the Revenue regarding the disallowance of TDS on payments made to foreign entities. The Tribunal confirmed that the payments were rightly treated as commission and not as fee for technical services, based on the previous decision in the assessee's own case for A.Y. 2010-11. The judgment emphasized the distinction between commission and fee for technical services, highlighting that the foreign entity did not have a Permanent Establishment in India and no technical knowledge was transferred, leading to the deletion of the disallowed amount. Case-Laws Income Tax Wed, 06 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301627