TaxTMI 
TaxTMI 
2004 (5) TMI 57
X X X X Extracts X X X X
X X X X Extracts X X X X
....ne 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 type of transactions: * Commission pay....
X X X X Extracts X X X X
X X X X Extracts X X X X
....g 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 submitted that the need for deduction of tax at source under....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 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 , and that there may not be any need to deduct tax at source....