https://www.taxtmi.com/caselaws?id=782531 ITAT Delhi-AT dismissed the Revenue's appeal. It upheld CIT(A)'s finding that Section 14A r.w. Rule 8D could not be invoked as no exempt income actually arose during the year and the assessee's suo motu disallowance was not shown to be incorrect. On the TDS issue under Section 195 and the resultant disallowance under Section 40(a)(ia), the Tribunal agreed that payments to foreign vendors for conference charges, sponsorships, fees, subscriptions, and staff training related to services utilized outside India, were not taxable in India and did not constitute royalty or FIS under the DTAA, and reimbursements contained no income element. en-us Fri, 28 Nov 2025 00:00:00 +0530 Mon, 01 Dec 2025 08:50:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782531 ITAT Delhi-AT dismissed the Revenue's appeal. It upheld CIT(A)'s finding that Section 14A r.w. Rule 8D could not be invoked as no exempt income actually arose during the year and the assessee's suo motu disallowance was not shown to be incorrect. On the TDS issue under Section 195 and the resultant disallowance under Section 40(a)(ia), the Tribunal agreed that payments to foreign vendors for conference charges, sponsorships, fees, subscriptions, and staff training related to services utilized outside India, were not taxable in India and did not constitute royalty or FIS under the DTAA, and reimbursements contained no income element. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782531