Section 263 Revision: Non-deduction of TDS on Brokerage to Non-Resident Brokers Upheld; Key Documentation Issues Highlighted.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Revision u/s 263 - Non deduction of TDS u/s 195 on brokerage pad to non-resident brokers - This fact is admitted by assessee as in the paperbook index it is mentioned that the declaration by the parties of not having any permanent establishment in India along with their tax residency certificates have not been filed before the AO and have been filed only for the first time before ld. Pr. CIT. - Revision proceedings sustained - AT....