https://www.taxtmi.com/caselaws?id=448596 ITAT Delhi held that assessee was not liable to deduct TDS under section 195 on payments made to parent company LG Korea and other overseas associated entities for purchase of raw materials, finished goods, and capital goods. The tribunal found that profit attribution to the alleged PE was purely notional, and assessee had already deducted TDS under section 192 on expatriate employee salaries. Since no direct payment was made to LG Korea for salary costs and the PE profit attribution was based on notional income, assessee could not be expected to compute TDS on notional payments. Following Samsung India Electronics precedent, demands under sections 201(1)/201(1A) were deleted. en-us Tue, 21 Nov 2023 00:00:00 +0530 Wed, 24 Jan 2024 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448596 ITAT Delhi held that assessee was not liable to deduct TDS under section 195 on payments made to parent company LG Korea and other overseas associated entities for purchase of raw materials, finished goods, and capital goods. The tribunal found that profit attribution to the alleged PE was purely notional, and assessee had already deducted TDS under section 192 on expatriate employee salaries. Since no direct payment was made to LG Korea for salary costs and the PE profit attribution was based on notional income, assessee could not be expected to compute TDS on notional payments. Following Samsung India Electronics precedent, demands under sections 201(1)/201(1A) were deleted. Case-Laws Income Tax Tue, 21 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448596