https://www.taxtmi.com/caselaws?id=449633 Sales commission paid to a US subsidiary was treated as non-taxable fees for technical services because the services were sales and marketing support, not technical, managerial or consultancy services, and the India-USA DTAA make-available test was not satisfied; no tax deduction at source was therefore required under section 40(a)(i). ESOP-related expenditure was considered deductible business expenditure under section 37(1) because it represented an ascertained business liability and not a contingent or capital outlay. Provision for doubtful debts was also allowable where the amount was reduced from sundry debtors in the books, constituting an actual write-off under section 36(1)(vii). en-us Fri, 19 Jan 2024 00:00:00 +0530 Tue, 26 Nov 2024 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449633 Sales commission paid to a US subsidiary was treated as non-taxable fees for technical services because the services were sales and marketing support, not technical, managerial or consultancy services, and the India-USA DTAA make-available test was not satisfied; no tax deduction at source was therefore required under section 40(a)(i). ESOP-related expenditure was considered deductible business expenditure under section 37(1) because it represented an ascertained business liability and not a contingent or capital outlay. Provision for doubtful debts was also allowable where the amount was reduced from sundry debtors in the books, constituting an actual write-off under section 36(1)(vii). Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449633