https://www.taxtmi.com/caselaws?id=769834 ITAT Delhi allowed the assessee's appeal regarding interest-free loans to subsidiary, holding that commercial expediency extends beyond loss-making scenarios and transition to marginal profit doesn't eliminate such requirement. The tribunal directed deletion of interest disallowance. For TDS issues, the matter was remanded to AO for verification of deposited TDS. Regarding payments to foreign nationals, ITAT ruled services rendered outside India for less than 120 days weren't taxable in India under DTAA provisions, making TDS deduction unnecessary. The tribunal deleted disallowances, rejecting AO's requirement for section 195(2) certificate applications for non-taxable payments to non-residents. en-us Fri, 25 Apr 2025 00:00:00 +0530 Fri, 02 May 2025 08:54:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769834 ITAT Delhi allowed the assessee's appeal regarding interest-free loans to subsidiary, holding that commercial expediency extends beyond loss-making scenarios and transition to marginal profit doesn't eliminate such requirement. The tribunal directed deletion of interest disallowance. For TDS issues, the matter was remanded to AO for verification of deposited TDS. Regarding payments to foreign nationals, ITAT ruled services rendered outside India for less than 120 days weren't taxable in India under DTAA provisions, making TDS deduction unnecessary. The tribunal deleted disallowances, rejecting AO's requirement for section 195(2) certificate applications for non-taxable payments to non-residents. Case-Laws Income Tax Fri, 25 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769834