https://www.taxtmi.com/caselaws?id=760264 ITAT Bangalore ruled in favor of the assessee on two key issues. Regarding TDS under section 195, the tribunal held that no tax deduction was required on sales commission paid to Manthan Systems Inc., as the services did not fall under FTS or Article 12 of DTAA, following consistent decisions in assessee's earlier years (AYs 2012-13 to 2015-16). Consequently, no disallowance under section 40(a)(ia) was warranted. For ESOP expenses, the tribunal upheld CIT(A)'s decision allowing the deduction, citing established precedent from coordinate bench decisions in assessee's previous assessment years. en-us Tue, 15 Oct 2024 00:00:00 +0530 Thu, 17 Oct 2024 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760264 ITAT Bangalore ruled in favor of the assessee on two key issues. Regarding TDS under section 195, the tribunal held that no tax deduction was required on sales commission paid to Manthan Systems Inc., as the services did not fall under FTS or Article 12 of DTAA, following consistent decisions in assessee's earlier years (AYs 2012-13 to 2015-16). Consequently, no disallowance under section 40(a)(ia) was warranted. For ESOP expenses, the tribunal upheld CIT(A)'s decision allowing the deduction, citing established precedent from coordinate bench decisions in assessee's previous assessment years. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760264