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    <title>2018 (10) TMI 1955 - GUJARAT HIGH COURT</title>
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    <description>The Tribunal ruled in favor of the assessee in a case involving disallowances under sections 40(a)(ia) and 32(1)(ii) of the Income Tax Act. Regarding non-deduction of tax on commission paid to foreign agents, the Tribunal held that as the agents had no permanent establishment in India and their activities were outside India, no tax deduction was required. In the matter of depreciation on non-compete fees, the Tribunal upheld the claim, stating that the fees constituted depreciable intangible assets providing enduring benefits. The Revenue&#039;s appeals were dismissed, and the assessee&#039;s positions on both issues were supported.</description>
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    <pubDate>Tue, 09 Oct 2018 00:00:00 +0530</pubDate>
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      <title>2018 (10) TMI 1955 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=302619</link>
      <description>The Tribunal ruled in favor of the assessee in a case involving disallowances under sections 40(a)(ia) and 32(1)(ii) of the Income Tax Act. Regarding non-deduction of tax on commission paid to foreign agents, the Tribunal held that as the agents had no permanent establishment in India and their activities were outside India, no tax deduction was required. In the matter of depreciation on non-compete fees, the Tribunal upheld the claim, stating that the fees constituted depreciable intangible assets providing enduring benefits. The Revenue&#039;s appeals were dismissed, and the assessee&#039;s positions on both issues were supported.</description>
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      <pubDate>Tue, 09 Oct 2018 00:00:00 +0530</pubDate>
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