https://www.taxtmi.com/caselaws?id=774987 The Bombay HC dismissed a revenue appeal concerning TDS disallowance under section 40(a)(i) for non-deduction on foreign remittances to non-residents for destination sampling and ore analysis services rendered outside India. The court applied CBDT Circular No. 5/2024 establishing threshold limits for government appeals, noting the tax effect was below Rs. 2 crores. A Division Bench previously ruled that paragraph 3.1(l) exceptions apply only to litigation arising from orders under sections 201/201(1A), not section 143(3) assessments. Since the present appeal originated from assessment under section 143(3) rather than section 201, the exclusion in paragraph 3.1(l) was inapplicable. The court bound itself to the earlier Division Bench decision and dismissed the appeal based on the threshold limits prescribed in the circular. en-us Wed, 25 Jun 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774987 The Bombay HC dismissed a revenue appeal concerning TDS disallowance under section 40(a)(i) for non-deduction on foreign remittances to non-residents for destination sampling and ore analysis services rendered outside India. The court applied CBDT Circular No. 5/2024 establishing threshold limits for government appeals, noting the tax effect was below Rs. 2 crores. A Division Bench previously ruled that paragraph 3.1(l) exceptions apply only to litigation arising from orders under sections 201/201(1A), not section 143(3) assessments. Since the present appeal originated from assessment under section 143(3) rather than section 201, the exclusion in paragraph 3.1(l) was inapplicable. The court bound itself to the earlier Division Bench decision and dismissed the appeal based on the threshold limits prescribed in the circular. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774987