https://www.taxtmi.com/caselaws?id=754608 ITAT DELHI - AT restored the issue of deduction for brought-forward losses/unabsorbed depreciation under section 115JB to the AO for fresh factual verification and computation. On TDS under section 195, the Tribunal held payments to non-residents from USA, UK, Australia, Canada and Singapore were not taxable in India (no make-available/PE; treaty relief applies) and no withholding was required; payments to UAE residents likewise not taxable under the India-UAE treaty. For Netherlands, Spain and France, facts showed repairs were performed abroad and no PE existed, so no withholding obligation. Addition for advances written off was deleted and the ground dismissed. en-us Wed, 31 Jan 2024 00:00:00 +0530 Sat, 25 Oct 2025 13:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754608 ITAT DELHI - AT restored the issue of deduction for brought-forward losses/unabsorbed depreciation under section 115JB to the AO for fresh factual verification and computation. On TDS under section 195, the Tribunal held payments to non-residents from USA, UK, Australia, Canada and Singapore were not taxable in India (no make-available/PE; treaty relief applies) and no withholding was required; payments to UAE residents likewise not taxable under the India-UAE treaty. For Netherlands, Spain and France, facts showed repairs were performed abroad and no PE existed, so no withholding obligation. Addition for advances written off was deleted and the ground dismissed. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754608