https://www.taxtmi.com/caselaws?id=764903 The ITAT Chennai ruled in favor of the assessee on two key issues. First, it upheld the CIT(A)'s decision to delete the disallowance under Section 40(a)(i) of the Income Tax Act, agreeing that payments for software services to non-residents did not require tax deduction at source, following precedents set by the SC and HC of Madras. Second, the Tribunal affirmed the use of the average LIBOR rate for computing the Arm's Length Price of outstanding receivables from associated enterprises, dismissing the revenue's preference for the SBI PLR rate. Both appeals by the revenue were dismissed. en-us Wed, 15 Jan 2025 00:00:00 +0530 Tue, 21 Jan 2025 09:16:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764903 The ITAT Chennai ruled in favor of the assessee on two key issues. First, it upheld the CIT(A)'s decision to delete the disallowance under Section 40(a)(i) of the Income Tax Act, agreeing that payments for software services to non-residents did not require tax deduction at source, following precedents set by the SC and HC of Madras. Second, the Tribunal affirmed the use of the average LIBOR rate for computing the Arm's Length Price of outstanding receivables from associated enterprises, dismissing the revenue's preference for the SBI PLR rate. Both appeals by the revenue were dismissed. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764903