https://www.taxtmi.com/caselaws?id=771114 ITAT Jaipur ruled on three issues: (1) TDS u/s 195 - Commission paid to foreign agents for services rendered outside India not chargeable to tax under section 5(2), hence no TDS liability and section 40(a)(i) disallowance deleted; (2) Addition u/s 14A - No disallowance permissible where no exempt income earned, following SC precedent in GVK Project case, addition set aside; (3) CSR expenses - Disallowance upheld as assessee failed to prove expenses were incurred wholly and exclusively for business purposes under section 37(1), despite claiming section 80G deduction availability. en-us Tue, 08 Apr 2025 00:00:00 +0530 Tue, 20 May 2025 10:45:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771114 ITAT Jaipur ruled on three issues: (1) TDS u/s 195 - Commission paid to foreign agents for services rendered outside India not chargeable to tax under section 5(2), hence no TDS liability and section 40(a)(i) disallowance deleted; (2) Addition u/s 14A - No disallowance permissible where no exempt income earned, following SC precedent in GVK Project case, addition set aside; (3) CSR expenses - Disallowance upheld as assessee failed to prove expenses were incurred wholly and exclusively for business purposes under section 37(1), despite claiming section 80G deduction availability. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771114