2009 (11) TMI 950

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....am O R D E R Per N.R.S.Ganesan, Judicial Member: This appeal of the Revenue is directed against the order of the CIT (Appeals) V, Hyderabad, and pertains to asst. year 2003-04. The only issue that arises for consideration in this appeal is disallowance of Rs. 38,34,905 on the ground that the assessee failed to deduct tax at source while making payment outside India. 2. Shri H.Phani Raj....

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....arned representative for the assessee, submitted that no payments were made in India. The foreign agents have no permanent establishment in India. According to the learned representative, the entire payments were made in US $ by a branch office situated outside India. The entire services were rendered only outside India. In those circumstances, according to the learned representative, the provisio....