https://www.taxtmi.com/caselaws?id=464269 ITAT CHENNAI - AT dismissed the Revenue's appeal. The tribunal upheld the CIT(A)'s finding that export commission payments to overseas agents did not constitute fees for technical services under s.9(1)(vii), rejecting the AO's TDS demand for s.195. On development charges for SIPCOT 99-year leasehold, the tribunal agreed that the 5% annual retention credited by the lessor reduces the lump-sum development charge and is properly expensed annually, not required to be amortized, so disallowance was rejected. en-us Fri, 06 Feb 2015 00:00:00 +0530 Wed, 15 Oct 2025 20:49:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464269 ITAT CHENNAI - AT dismissed the Revenue's appeal. The tribunal upheld the CIT(A)'s finding that export commission payments to overseas agents did not constitute fees for technical services under s.9(1)(vii), rejecting the AO's TDS demand for s.195. On development charges for SIPCOT 99-year leasehold, the tribunal agreed that the 5% annual retention credited by the lessor reduces the lump-sum development charge and is properly expensed annually, not required to be amortized, so disallowance was rejected. Case-Laws Income Tax Fri, 06 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464269