https://www.taxtmi.com/caselaws?id=448606 ITAT Delhi dismissed Revenue's appeal regarding TDS disallowance u/s 40(a)(i) for non-deduction on payments to non-resident for management and sales marketing support services. AO treated payments as FTS requiring TDS deduction. CIT(A) deleted addition holding services non-taxable under India-Netherlands DTAA with MFN clause benefits. ITAT upheld CIT(A)'s interpretation that since recipient's income was non-taxable, no TDS obligation existed u/s 195, consequently no disallowance u/s 40(a)(i) warranted. en-us Mon, 22 Jan 2024 00:00:00 +0530 Tue, 23 Jan 2024 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448606 ITAT Delhi dismissed Revenue's appeal regarding TDS disallowance u/s 40(a)(i) for non-deduction on payments to non-resident for management and sales marketing support services. AO treated payments as FTS requiring TDS deduction. CIT(A) deleted addition holding services non-taxable under India-Netherlands DTAA with MFN clause benefits. ITAT upheld CIT(A)'s interpretation that since recipient's income was non-taxable, no TDS obligation existed u/s 195, consequently no disallowance u/s 40(a)(i) warranted. Case-Laws Income Tax Mon, 22 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448606