https://www.taxtmi.com/caselaws?id=456626 ITAT Delhi held that payments to a German individual for professional services were not taxable in India under Article 14 of the India-Germany DTAA, as no permanent establishment existed and services were rendered outside India. No TDS liability arose under section 195(1), making section 40(a)(ia) inapplicable. However, payments to a UK entity for designing services constituted technical services under the India-UK DTAA, confirming the disallowance. Regarding interest disallowance on interest-free advances, the tribunal found the assessee had adequate non-interest bearing funds and established commercial expediency, ruling no nexus existed between borrowed funds and the advance, thereby deleting the disallowance. en-us Mon, 24 Apr 2017 00:00:00 +0530 Tue, 06 Aug 2024 20:13:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456626 ITAT Delhi held that payments to a German individual for professional services were not taxable in India under Article 14 of the India-Germany DTAA, as no permanent establishment existed and services were rendered outside India. No TDS liability arose under section 195(1), making section 40(a)(ia) inapplicable. However, payments to a UK entity for designing services constituted technical services under the India-UK DTAA, confirming the disallowance. Regarding interest disallowance on interest-free advances, the tribunal found the assessee had adequate non-interest bearing funds and established commercial expediency, ruling no nexus existed between borrowed funds and the advance, thereby deleting the disallowance. Case-Laws Income Tax Mon, 24 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456626