https://www.taxtmi.com/caselaws?id=762047 The Madras HC ruled in favor of the assessee on two key issues. First, regarding section 80IA deduction computation, the court followed SC precedent in Velayudhaswamy Spinning Mills Ltd, allowing unabsorbed depreciation and losses to be considered. Second, on disallowance of agency commission under section 40(a)(i), the court held that commission paid to non-resident agents abroad through banking channels was not subject to TDS requirements, citing CBDT Circular 786 that export commission is not taxable in India. en-us Tue, 05 Nov 2024 00:00:00 +0530 Fri, 22 Nov 2024 07:50:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762047 The Madras HC ruled in favor of the assessee on two key issues. First, regarding section 80IA deduction computation, the court followed SC precedent in Velayudhaswamy Spinning Mills Ltd, allowing unabsorbed depreciation and losses to be considered. Second, on disallowance of agency commission under section 40(a)(i), the court held that commission paid to non-resident agents abroad through banking channels was not subject to TDS requirements, citing CBDT Circular 786 that export commission is not taxable in India. Case-Laws Income Tax Tue, 05 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762047