2004 (5) TMI 57

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....tice Syed Shah Mohammed Quadri) - None appears for the applicant. The applicant M/s. Ind Telesoft Private Limited, Bangalore, a resident company, filed application under section 245Q(1) of the Income-tax Act, 1961 (for short the Act), seeking advance ruling of this authority on the following questions:- "Advance ruling is required for, whether tax at source is to be deducted for the following t....

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....on in India. The applicant company is however earning foreign exchange by export of developed software. After receipt of foreign exchange in India, the non-resident companies would be paid their commission and fees. 4. Notice of the application was sent to the Commissioner of Income-tax-I, Bangalore, the jurisdictional Commissioner, for his comments. By his letter of October 11, 2001, he submit....

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....nt companies. 5. A letter of the applicant is brought to our notice expressing inability to avail the opportunity of personal hearing afforded to it, it requested that the case be decided on merits. We also find on record a letter of the Commissioner of Income-tax, the jurisdictional Commissioner. It is reiterated in the said letter that no income arises to the said foreign agents in India , an....