https://www.taxtmi.com/caselaws?id=449633 ITAT Bangalore ruled in favor of the assessee on three issues. Regarding TDS under section 195 on sales commission to foreign company, the tribunal held no TDS liability existed as services didn't fall under FTS or Article 12 of DTAA, following precedent in Manthan System Inc. case. Addition under section 40(a)(i) was deleted. For ESOP expenses, following Karnataka HC's Biocon Ltd. judgment, expenses were allowed as revenue deduction under section 37(1) based on mercantile accounting and legal liability. Provision for doubtful debts was permitted following SC's Vijaya Bank precedent, with revenue's additions deleted. 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 ITAT Bangalore ruled in favor of the assessee on three issues. Regarding TDS under section 195 on sales commission to foreign company, the tribunal held no TDS liability existed as services didn't fall under FTS or Article 12 of DTAA, following precedent in Manthan System Inc. case. Addition under section 40(a)(i) was deleted. For ESOP expenses, following Karnataka HC's Biocon Ltd. judgment, expenses were allowed as revenue deduction under section 37(1) based on mercantile accounting and legal liability. Provision for doubtful debts was permitted following SC's Vijaya Bank precedent, with revenue's additions deleted. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449633